U.S. Privacy Policy

TABLE OF CONTENTS

1. Scope, Collection, Use, and Disclosure — Sections 1–4

2. Sale, Sharing, Cookies, and Payments — Sections 5–7

3. AI, Security, and Retention — Sections 8–10

4. Privacy Rights, Children, International Processing, and Changes — Sections 11–15

5. Notices at Collection and Privacy-Choice Implementation — Exhibits A–E

SMS Verification Privacy Supplement — September 15, 2026 (following Section 5)

This policy includes the SMS Verification Privacy Supplement dated September 15, 2026 below. Its protections for mobile information and SMS consent take precedence over broader sharing permissions elsewhere in this policy.

This Privacy Policy describes how Settlyfe Inc. collects, uses, discloses, retains, and protects personal information and the choices available to you.

1. Scope and Who We Are

1.1 Scope. This Privacy Policy explains how Settlyfe Inc. collects, uses, discloses, retains, and protects personal information in the Settlyfe Home Services customer website/app, provider website/app, support, Platform operations, and related communications. It does not govern a Provider Company’s independent records or services, although the Provider Company is contractually restricted in its use of Platform Transaction Data.

1.2 Roles. Settlyfe generally determines how Platform Account, matching, support, security, analytics, and marketplace data is processed. A Provider Company independently determines how it processes information necessary to quote and perform its direct Service, subject to its own legal duties, this Policy’s disclosures, the Provider Agreement, and Platform Rules.

1.3 Not consent to everything. This Policy provides transparency; it is not blanket consent. Settlyfe will request separate permission where required, including for marketing texts, recurring bank debits, device-level precise location, camera/microphone access, biometric uses, or materially different processing.

2. Personal Information We Collect

Settlyfe collects the categories below from the identified sources. Some information may constitute sensitive personal information under state law and is used or disclosed only for permitted or separately disclosed purposes.

3. How We Use Personal Information

Use outcome and correction signals—including accepted or declined opportunities, completion, cancellations, timing, estimates compared with actual scope, quality reports, disputes, fraud signals, and feedback—to test, evaluate, and improve matching, dispatch, pricing assistance, safety triage, support, and related models.

Create, authenticate, secure, and administer Accounts, roles, sessions, and permissions.

Receive Service requests; produce estimates; match or refer compatible Provider Companies; form and record Service Orders; support scheduling, access, completion, corrections, and claims.

Enable communications among Customers, Provider Companies, assigned Personnel, support, payment processors, and authorized property contacts.

Process payment authorizations, charges, refunds, payouts, disputes, fraud controls, taxes, and financial records through licensed processors.

Verify identity, business status, licenses, insurance, sanctions, safety eligibility, and compliance; do not describe verification more broadly than performed.

Provide customer support, Trust & Safety response, moderation, appeals, insurance cooperation, incident response, and legal compliance.

Measure, debug, secure, improve, and develop the Platform; evaluate Platform functionality; prevent scraping, account takeover, fraud, circumvention, and misuse.

Send transactional messages and, only with legally sufficient permission, optional marketing; honor revocation and opt-outs.

Comply with law, enforce contracts, protect rights and safety, respond to lawful process, establish or defend claims, and complete corporate transactions subject to safeguards.

4. When We Disclose Personal Information

4.1 Customers and Providers. We disclose job information between the Customer and the accepted Provider Company and only the assigned or authorized Personnel as needed. Before acceptance, Settlyfe will mask exact address and direct contact details before Provider acceptance. After the permitted period, Settlyfe will revoke or minimize access.

4.2 Vendors and processors. We may disclose information to cloud hosting, authentication, security, analytics, communications, maps, customer support, document, AI, credential-verification, background-screening, insurance, professional-adviser, and payment vendors under contracts appropriate to their role.

4.3 Legal and safety. We may disclose information when reasonably necessary to comply with valid law or process; protect a person, property, or Platform security; investigate fraud, harassment, injury, damage, or data misuse; enforce agreements; or cooperate with insurers, regulators, emergency responders, and law enforcement.

4.4 Business transfers. Information may be disclosed in diligence or transferred in a financing, merger, reorganization, acquisition, bankruptcy, or asset sale, subject to confidentiality, applicable notice, and privacy rights.

4.5 At your direction. We disclose information when you direct us, such as when you share a Service Order, add a property contact, choose a Provider, submit to an insurer, or enable an external integration.

5. Sale, Sharing, Advertising, and Analytics

5.1 Sale and sharing. Settlyfe may sell personal information or share personal information for cross-context behavioral advertising as those terms are defined by applicable privacy law, but only for the categories, recipients, and purposes disclosed in this Policy and the applicable Notice at Collection. Depending on the technologies and commercial programs in use, this may include disclosure of identifiers, internet or other electronic activity, approximate location, commercial information, and inferences to advertising, analytics, attribution, social-media, data-collaboration, or business partners. Settlyfe does not sell full payment credentials, account passwords, property access codes, identity-verification documents, background-check reports, precise location, biometric information, contents of private communications, or known information of a person under 16.

5.2 Your right to opt out. You may direct Settlyfe not to sell or share your personal information by selecting "Do Not Sell or Share My Personal Information" in the website footer or application Privacy Choices screen. You may also use the in-app Privacy Request form or contact support@settlyfe.com. The primary opt-out mechanism will not require you to create an Account, provide more information than reasonably necessary, or accept unrelated terms.

5.3 Global Privacy Control. Settlyfe treats a recognized opt-out preference signal, including Global Privacy Control, as a valid request to opt out of sale and sharing for the browser or device that sends the signal and, when Settlyfe can reasonably associate the signal with a known consumer, for that consumer. Settlyfe will not use a dark pattern or pop-up that asks a consumer to override the signal.

5.4 Effect and duration. Once Settlyfe receives a valid opt-out, it will stop covered sale and sharing as required and will not ask you to opt back in for at least 12 months unless law permits otherwise. An opt-out does not prevent disclosures to service providers or contractors for permitted business purposes, disclosures you direct, or other processing that privacy law does not define as sale or sharing.

5.5 Minors. Settlyfe does not knowingly sell or share personal information of consumers under 16 without the affirmative authorization required by law. The Platform is not directed to children under 13 and does not permit them to open Accounts.

5.6 Mobile-app limitation. Personal and sensitive user data obtained through a mobile application will not be sold in violation of the applicable app store's developer policies. Where an app-store rule is more restrictive than this Policy, Settlyfe will apply the more restrictive rule to data obtained through that application.

5.7 Financial incentives. If Settlyfe offers a program that may be a financial incentive or price or service difference under privacy law, Settlyfe will provide separate terms describing the material terms, value methodology, how to opt in, and how to withdraw before enrollment. Referral credits and ordinary service promotions are not permission to sell personal information unless the separate notice expressly says so.

5.8 Implementation and change control. Before activating a new advertising SDK, data collaboration, broker relationship, or other practice that may constitute sale or sharing, Settlyfe will update the applicable Notice at Collection, complete vendor and app-store review, configure consent and opt-out controls, and provide any required advance notice.

5.9 No provider marketing list. Provider Companies may not use Transaction Data to create marketing audiences, append unrelated data, or solicit Customers without separate lawful consent. Report unwanted outreach to Trust & Safety.

5.10 Sensitive-personal-information limitation. Settlyfe uses and discloses sensitive personal information only for purposes reasonably necessary to provide requested Services, verify and secure Accounts, process authorized payments, prevent and investigate fraud or safety incidents, comply with law, and other purposes permitted without a right to limit. If Settlyfe later uses sensitive personal information for a purpose that triggers a statutory right to limit or requires consent, Settlyfe will provide the required control before that use.

SMS Verification Privacy Supplement — September 15, 2026

Information and purpose. When you request a verification code, we process your mobile number and records of your SMS consent and verification, including the disclosure version and relevant timestamps. We use this information to deliver the requested code, verify your number, prevent abuse, honor messaging choices, and maintain consent records. Requesting a code does not authorize promotional texts.

No marketing sale or sharing. We do not sell, rent, or share mobile numbers or other mobile information with third parties or affiliates for marketing or promotional purposes. SMS opt-in data and consent are excluded from every general data-sharing permission elsewhere in this policy, including Sections 4 and 5 and the Notices at Collection. We do not share SMS opt-in data or consent with third parties or affiliates, except aggregators and providers of the text message service as necessary to deliver and manage this program. They may not use that information for their own marketing.

Service providers and contact details. We use messaging providers, including Twilio, and mobile carriers to deliver and manage verification messages. If your verified number is also your account contact number, it may be disclosed to the assigned Provider Company as needed for your requested Service under Section 4.1; that disclosure does not include your SMS opt-in or consent records and does not authorize marketing.

One message per verification-code request. Message and data rates may apply.

Your choices. Reply STOP to the sender to stop verification texts or HELP for assistance. You can also contact support@settlyfe.com about messaging or privacy. The SMS Verification Supplement in the User Agreement at https://settlyfe.com/legal/home-services/user-agreement explains message frequency, rates, help, and the effect of opting out.

6. Cookies, SDKs, and Device Permissions

6.1 Essential technologies. We may use cookies, local storage, mobile SDKs, pixels, logs, and similar technologies for login, security, preferences, routing, fraud prevention, performance, and Platform analytics. Settlyfe evaluates these technologies by provider, duration, data, purpose, contractual role, and available opt-out.

6.2 Device permissions. Camera, photo library, notifications, microphone, contacts, Bluetooth, and location are controlled by the device. Settlyfe will request a permission in context and use the resulting data only as described. You may revoke it in device settings, although a feature may stop working.

6.3 Advertising choices. Cookie and SDK controls supplement, but do not replace, the sale/sharing opt-out in Section 5. Disabling a browser cookie may not affect another browser or application unless the request is associated with your Account as permitted by law.

7. Payments and Financial Information

7.1 Processor handling. Settlyfe does not intentionally receive full card or bank credentials when its payment processor can tokenize them. The processor independently handles payment credentials under its privacy policy; Settlyfe receives transaction status, tokenized identifiers, limited card descriptors, payout status, fraud signals, and records needed for support, accounting, and disputes.

7.2 Recurring charges. A recurring Customer Service charge is processed only after separate acceptance of the Recurring Service Plan Addendum and Plan Summary. ACH, debit-card, and other payment mandates receive any separate authorization and copy required by applicable law and processor rules.

7.3 No escrow claim. Payment authorization, delayed capture, processor balance, payout review, or reserve is not described as escrow unless a licensed, operational, and separately disclosed escrow structure actually exists.

8. AI and Automated Processing

8.1 Uses. Automated tools may categorize requests, suggest questions, estimate price ranges, rank compatible Providers, summarize messages, identify possible fraud or safety anomalies, and assist support. Outputs may be reviewed by people and are not guaranteed accurate.

8.2 Sensitive and consequential decisions. Settlyfe will not use a general-purpose model to make a solely automated, legally significant decision about employment, housing, credit, insurance, safety eligibility, or access without the notices, testing, human review, correction, and opt-out required by applicable law.

8.3 Settlyfe model training and improvement. Settlyfe may use eligible Account, request, quote, service, message, photo, review, support, dispatch, completion, cancellation, quality, fraud, device, and usage information to create, train, fine-tune, test, evaluate, validate, and improve models and automated systems that support Settlyfe products and services. These systems may concern classification, matching, ranking, scheduling, dispatch, price and scope assistance, personalization, safety, fraud, moderation, customer support, forecasting, and product development. Settlyfe may conduct this processing using its own systems or contracted service providers/processors.

8.4 Restrictions on training data. Unless Settlyfe gives a specific notice and obtains any authorization required by law, Settlyfe excludes full payment credentials, passwords, property access codes, identity or license documents, background-check reports, biometric identifiers, precise location history, health information, known children's data, and the contents of identifiable private communications or private-home images from general-purpose or shared-model training. Such data may still be processed when necessary to provide the requested feature, secure the Platform, investigate an incident, comply with law, or resolve a transaction.

8.5 External model providers. Settlyfe may disclose the minimum information reasonably necessary to an AI or infrastructure provider acting under contract to supply an AI-enabled feature or model-development service. Unless separately disclosed and lawfully authorized, the provider may not use identifiable Transaction Data to train a general model for its own purposes or for unrelated customers.

8.6 AI choices. Where applicable law provides an opt-out from eligible AI model-development processing, Settlyfe will make that choice available through Privacy Choices or the Privacy Request form. An AI-training objection or opt-out does not prevent operational processing that is necessary to deliver a requested feature or transaction, protect safety and security, comply with law, or establish and defend legal claims.

8.7 No model guarantee. Automated outputs may be incomplete, inaccurate, biased, unavailable, or unsuitable for a particular property or decision. They are informational and do not replace licensed professional judgment, inspection, legal requirements, or human review where required.

8.8 Deidentified and aggregated model data. Settlyfe may use, retain, disclose, license, commercialize, and sell deidentified or aggregated data, model inputs, evaluation results, statistics, insights, and outputs, subject to applicable deidentification requirements.

8.9 Significant decisions. Settlyfe will provide legally required pre-use notice, access information, opt-out or exception, risk assessment, and human review before using automated decisionmaking technology to make a significant decision about a consumer when applicable law requires those measures.

8.10 Governance. Settlyfe may log prompts, outputs, feedback, and safety events to evaluate performance, prevent misuse, debug, audit, and improve systems. Access is limited according to role and retention need.

8.11 Transparency and risk controls. Where required, Settlyfe will provide a pre-use notice describing the purpose of automated processing, the information used, principal logic or factors at an appropriate level, intended output, human involvement, known material limitations, and available rights. Settlyfe may conduct and retain legally required risk assessments, testing, cybersecurity audits, bias or performance evaluations, and decision records without disclosing trade secrets or information that would defeat security.

9. Retention

9.0 Retention criteria. Settlyfe uses category-specific retention periods based on Account status, transaction lifecycle, warranty and dispute windows, chargeback and tax requirements, safety evidence, legal holds, security needs, processor obligations, and the time needed for the disclosed purpose. Sensitive access instructions and precise active-job location should be deleted or deidentified promptly after the operational need ends; identity, payment, tax, and incident records may require longer periods.

9.1 General rule. We retain personal information only as reasonably necessary for the disclosed purpose, Account and transaction administration, security, dispute and warranty periods, legal obligations, and establishment or defense of claims. We then delete, deidentify, or isolate it unless continued retention is required.

These are the Home Services Platform retention periods. Settlyfe may shorten a period when records are no longer needed or retain longer when a legal hold, claim, regulator, tax rule, security need, or other law requires it.

10. Security

10.1 Safeguards. Settlyfe uses administrative, technical, and physical safeguards designed to be appropriate to the data and risk, including access controls, authentication, encryption in transit, appropriate encryption at rest, logging, backups, vulnerability management, vendor diligence, incident response, and Personnel training. No transmission or storage method is completely secure, and Settlyfe does not promise “bank-level,” perfect, or breach-proof security.

10.2 User responsibilities. Use unique credentials, enable available multifactor authentication, secure devices, restrict personnel access, avoid sending access codes through unapproved channels, and report suspicious activity promptly.

10.3 No absolute security. No transmission or storage system is perfectly secure. Settlyfe will not promise that all data is always encrypted or “bank-level secure” without a current technical basis and qualification.

10.4 Incident notices. If a security incident occurs, Settlyfe will investigate, mitigate, document, and notify affected persons, regulators, or others as required by applicable law. Provider Companies must report Transaction Data incidents within 24 hours under their agreement.

11. Your Choices and Rights

11.1 Account and communications. You may update Account information, device permissions, and communication preferences through settings or support. Transactional messages necessary for an active order may continue even after a marketing opt-out.

11.2 California rights. Subject to scope and exceptions, California residents may request access to categories and specific pieces of personal information, correction, deletion, and information about collection and disclosure; opt out of sale or sharing; limit certain uses and disclosures of sensitive personal information; and receive equal service and pricing without unlawful discrimination for exercising a privacy right.

11.3 Exercising rights. Use the in-app Privacy Request form, Privacy Choices screen, website footer link, or support@settlyfe.com. Sale/sharing opt-outs and limit requests will not require identity verification beyond what applicable law permits. Access, correction, and deletion requests may require proportionate verification. Settlyfe will support authorized agents, explain denials, and provide appeal rights where required. Do not send identity documents by ordinary email unless instructed through a secure method.

11.4 Appeals and complaints. Where state law provides an appeal, you may appeal through the same channel with subject “Privacy Appeal.” You may also contact the California Privacy Protection Agency, California Attorney General, or another competent regulator.

11.5 Marketing revocation. You may revoke marketing text/call consent by any reasonable method recognized by law, including replying STOP where supported. Marketing email includes an unsubscribe mechanism. A Provider Company is responsible for its independent campaigns, but Settlyfe will enforce Platform Rules for misuse of Transaction Data.

11.6 Additional U. S. state rights. Depending on your state and applicable law, you may also have rights to confirm processing, obtain a portable copy, obtain a list of certain third parties, opt out of targeted advertising, sale, or qualifying profiling, withdraw consent, restrict sensitive-data processing, correct inaccuracies, delete information, and appeal a denied request. Settlyfe will apply the rights and exceptions required for your verified residency and the processing at issue.

11.7 No unlawful discrimination. Settlyfe will not unlawfully discriminate or retaliate because you exercise a privacy right. A lawful financial-incentive or price-difference program, if any, will use separate terms and notice as required.

12. Children

12.1 Adult service. The Platform is not directed to children under 13 and Accounts require an adult. Do not submit a child’s information unless reasonably necessary for a Service and legally authorized. Avoid identifiable child images in job photos.

12.2 Deletion. Contact support@settlyfe.com if you believe a child provided information without required permission. Settlyfe will investigate and delete as appropriate.

13. International Processing

13.1 United States service. The Platform is directed to users in the United States. Settlyfe and its vendors may process information in the United States and other locations where they operate, subject to applicable contractual and security safeguards. Access from another country does not mean Settlyfe offers the Platform there.

14. Changes to This Policy

14.1 Notice and effective date. We will post the current version and effective date. Material changes receive advance notice and, when required, consent before the new processing. We will not retroactively use sensitive Transaction Data for a materially incompatible purpose without legal authority.

15. Contact

15.1 Privacy contact. Email support@settlyfe.com or use the in-app Privacy Request form. Mail privacy correspondence to 15617 Pumpkin Pl, Fontana, CA 92336. The in-app request flow and support@settlyfe.com are the accessible request methods for the Platform.

Exhibit A — Notice at Collection

Display this short notice at or before collection, with a conspicuous link to the full Privacy Policy.

Notice at Collection: Settlyfe collects identifiers and Account data; provider business and credential data; service requests; property addresses and access instructions; photos, messages, and support content; commercial and payment-status data; device, network, usage, and approximate-location data; optional precise location; inferences; and safety, fraud, and legal information. We use these categories to operate, personalize, secure, analyze, advertise, develop, and improve Settlyfe and its AI and automated systems; match and support Services; communicate; process payments; verify Providers; prevent misuse; and comply with law. We disclose information to the accepted Provider Company and authorized Personnel, service providers and contractors, advertising and analytics partners, business partners, professional advisers, and authorities as described in the Privacy Policy. Settlyfe may sell or share identifiers, electronic activity, approximate location, commercial information, and inferences as described in Section 5. You may opt out through 'Do Not Sell or Share My Personal Information,' Privacy Choices, or a recognized Global Privacy Control signal. We do not sell the sensitive categories identified in Section 5.1. See the Privacy Policy for retention and rights or contact support@settlyfe.com.

Exhibit B — AI and Model-Improvement Notice at Collection

Categories: Account and profile data; service-request and scope data; quote and pricing inputs; availability and dispatch events; communications and support metadata; job photos and messages when a feature requires them; completion, cancellation, quality, fraud, dispute, and feedback signals; device, approximate location, and active-job precise location when enabled.

Operational purposes: provide Accounts and features; match eligible parties; generate estimates or suggestions; support Provider-configured dispatch; facilitate payment and support; secure the Platform; detect fraud and misuse; investigate safety and quality incidents; comply with law.

Improvement purposes: evaluate and improve matching, dispatch, pricing assistance, ETA, fraud, quality, support, and other Platform models using deidentified or aggregated information and appropriately controlled examples. Raw sensitive or identifiable private content is excluded from general/shared-model training by default as described in Section 8.

Choices: device permissions; marketing opt-out; privacy requests; correction and appeal channels; and any feature-specific training choice required for a materially broader use. Declining an optional AI-training choice will not prevent necessary processing for an accepted transaction, security, or law.

Exhibit C — User Content, Reviews, Feedback, and AI Notice at Collection

When you submit a review, rating, message, photo, video, audio recording, document, profile, service description, support request, prompt, feedback, proposal, or other content, Settlyfe collects the content and associated Account, transaction, device, timing, location, engagement, moderation, and rights-management information.

Settlyfe uses this information to provide and display the selected feature; facilitate and document Services; communicate; moderate content; investigate safety, fraud, infringement, and policy violations; resolve disputes; enforce agreements; personalize and improve products; and create, train, fine-tune, test, evaluate, validate, monitor, and improve Settlyfe AI, matching, ranking, pricing-assistance, dispatch, fraud, safety, support, and automation systems.

Depending on the feature and your selections, content may be visible to the public, Customers, Provider Companies, assigned Personnel, property contacts, business administrators, support teams, service providers, AI/model providers acting under contract, professional advisers, or authorities. Do not submit another person's confidential, copyrighted, private, or sensitive information unless you have lawful authority and it is reasonably necessary for the feature.

Settlyfe may retain transaction, safety, fraud, rights-management, consent, dispute, and legal records after content is removed or an Account is closed. Deidentified or aggregated information may be retained and commercialized as described in this Policy. The User-Generated Content Policy governs content rights and moderation; the Feedback and Unsolicited Ideas Policy governs product ideas and proposals; and the Copyright and Trademark Policy governs infringement complaints.

Available privacy choices, including sale/sharing opt-out, Global Privacy Control, access, correction, deletion, sensitive-information limitations, and legally required AI choices, are described in Sections 5 and 11. A request to delete content remains subject to transaction records, safety, fraud, legal holds, other users' rights, and other lawful exceptions.

Exhibit D — California Sale and Sharing Disclosure

Exhibit E — Privacy Choices and Implementation Notice

Privacy Choices must provide, as applicable: (a) Do Not Sell or Share My Personal Information; (b) recognized opt-out preference signal processing, including Global Privacy Control; (c) access, correction, deletion, portability, and appeal requests; (d) limit or withdraw consent for sensitive information where required; (e) marketing communication preferences; and (f) any legally required automated-decision or AI choice.

The website footer and each mobile application must link to Privacy Choices. A choice must be honored across the browser, device, and Account to the extent Settlyfe can reasonably associate them and law requires. Settlyfe will maintain request, verification, response, suppression, and appeal records for the legally required period.

Mandatory-Law Savings

To the maximum extent permitted by law, each disclaimer, release, indemnity, limitation, remedy, choice-of-law provision, and arbitration provision is subject to non-waivable law, including California Civil Code section 1668.