Draft — pending legal review

Privacy Policy

Last updated April 27, 2026

1. Who We Are

This Privacy Policy describes how Malama Funding LLC (“RaiseAppraisal,” “we,” “us,” or “our”) collects, uses, shares, and protects your personal information when you visit raiseappraisal.com or use our software-as-a-service product (collectively, the “Service”).

Team
RaiseAppraisal.com — Privacy Team
Mail
Malama Funding LLC, [street address], [city], CA [zip]

2. The Short Version (Plain English)

  • We collect what we need to run the Service: your account info, your payment info (handled by Stripe), and the appraisal documents you upload.
  • We use AI (Claude and Gemini) to analyze appraisals you upload. Those vendors do not train their models on your data.
  • We do not sell or rent your personal information to anyone for advertising.
  • We do use a small set of analytics tools to understand how the Service is used.
  • We delete your uploaded PDFs after 90 days. We may retain de-identified data (with names, addresses, and loan numbers stripped) longer to improve our software.
  • You can request access to, correction of, deletion of, or a copy of your data anytime by emailing privacy@raiseappraisal.com. We respond within 45 days.

3. Information We Collect

3.1 Information You Provide

CategoryExamples
Account infoName, email address, password (hashed), phone (optional)
Subscription / payment infoBilling address; payment method (handled by Stripe — we never see your full card number)
Uploaded documentsAppraisal PDFs you upload, which may contain: borrower names, property addresses, appraiser names and license numbers, loan numbers, comparable sale data, valuation details
CommunicationsEmails you send to support, feedback you submit
User-supplied dataComparables you submit, market context, ROV reasoning

3.2 Information Collected Automatically

CategoryExamples
Usage dataPages visited, features used, ROVs generated, downloads, login times
Device dataBrowser type, operating system, IP address (anonymized for analytics), device type
CookiesSee our Cookie Policy for details

3.3 Information from Third Parties

SourceInformation
StripePayment processing status, billing zip for tax calculation
Real estate data providers (SFRA, Redfin, Zillow, Realtor.com, HUD)Public-record property and comparable sale data, used to enrich your analyses
Geocoding providers (Google Maps, OpenStreetMap)Address verification and property coordinates

4. How We Use Your Information

We use the information we collect to:

  1. Operate the Service — process your appraisal uploads, generate ROV documents, deliver them to you.
  2. Process payments — through Stripe; we never store your full card number.
  3. Communicate with you — confirmation emails, renewal reminders, dunning notices, support replies.
  4. Send marketing communications — only if you affirmatively opted in (we use double opt-in). You can unsubscribe anytime.
  5. Improve the Service — using de-identified, anonymized data only (see Section 7).
  6. Comply with legal obligations — tax, audit, regulatory, and law enforcement requests.
  7. Protect the Service and our users — fraud prevention, abuse detection, security monitoring.

5. How We Share Your Information

We do not sell or rent your personal information. We share it only as described below.

5.1 Service Providers (Sub-Processors)

We share information with vendors who help us run the Service. Each is contractually required to use your data only for the services they provide to us. See the full Sub-Processor List. Key categories include:

CategoryVendorsWhat They Receive
Hosting & infrastructureVercelAll Service data (encrypted at rest)
DatabaseVercel Postgres / managed providerAccount, subscription, and analysis data
File storageVercel BlobUploaded appraisal PDFs (encrypted at rest)
Payment processingStripe (incl. Stripe Tax)Billing info, payment method, transaction data
AI processingAnthropic (Claude), Google (Gemini)Appraisal text content for analysis
Real estate dataSFRA, RapidAPI (Redfin/Zillow/Realtor), HUDProperty addresses and coordinates
Email deliveryPostmark / Resend / SendGridEmail addresses and email content
Product analyticsPostHog / MixpanelAnonymized usage events
Marketing analyticsGoogle Analytics 4 (IP-anonymized), Meta Conversions API (server-side, Limited Data Use mode)Conversion events; no personally identifying ad-targeting data
Customer supportHelp-desk softwareSupport tickets and your communications with us

5.2 AI Vendors — Important Notes

  • Anthropic and Google do not train their models on data sent through their APIs. This is an explicit contractual commitment in their API terms of service.
  • We process appraisal content (which may include borrower names and property data) through these APIs to generate ROV analyses. This is the core function of the Service.
  • Data is sent over encrypted (HTTPS/TLS) connections.

5.3 Legal & Safety

We may share information when we believe in good faith that disclosure is necessary to:

  • Comply with applicable law, legal process, or government request
  • Enforce our Terms of Service
  • Protect our rights, property, or safety, or that of our users or the public
  • Detect, prevent, or address fraud, security, or technical issues

5.4 Business Transfers

If RaiseAppraisal is involved in a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction. We will notify you (by email and/or prominent website notice) of any change in ownership or use of your information.

5.5 What We Do NOT Do

  • We do not sell your personal information to data brokers or advertisers.
  • We do not share your uploaded appraisal documents with anyone other than as described above.
  • We do not provide your information to credit bureaus or consumer reporting agencies.
  • We do not perform retargeting or behavioral advertising using cookies or pixels in a way that constitutes “selling” or “sharing” under California law.

6. Cookies & Tracking

We use cookies and similar technologies for:

  • Essential Service operation (login sessions, security)
  • Analytics (Google Analytics 4 with IP anonymization, PostHog)
  • Conversion tracking (Stripe; Meta Conversions API server-side)

We do not use cookies for cross-site advertising or behavioral retargeting. See our full Cookie Policy for details and opt-out instructions.

7. Data Retention & Deletion

We retain personal information for as long as needed to provide the Service and to satisfy our legal obligations.

7.1 Retention Schedule

Data TypeRetention Period
Uploaded appraisal PDFs90 days from upload, then permanently deleted
Generated ROV documentsWhile account is active + 90 days after cancellation
Account data (name, email, billing)While account is active + 5 years (litigation/audit)
Subscription / billing records7 years (tax compliance)
Email communications5 years
Audit logs (signups, cancellations, state changes)5 years (class action defense window)
De-identified data for AI improvementIndefinitely, in de-identified form only (see Section 7.2)

7.2 De-Identified Data for AI Improvement

To continuously improve our software, we retain certain extracted data points after stripping all of the following identifiers (HIPAA Safe Harbor standard):

  • Names (borrower, appraiser, AMC, lender)
  • Street addresses and exact GPS coordinates (we retain only ZIP code or higher)
  • Loan numbers, account numbers
  • Phone numbers, email addresses, fax numbers
  • Dates more granular than month + year
  • License numbers, file numbers, identifying URLs
  • Any other unique identifying number or characteristic

We use this de-identified data to:

  • Improve our flagging and analysis algorithms
  • Validate ROV strategy effectiveness in aggregate
  • Train internal models (not third-party AI)

We do NOT use your data to train Anthropic or Google's AI models — those vendors contractually do not train on API customer data.

If you want to opt out of de-identified data retention, contact privacy@raiseappraisal.com. Note: opting out may limit some forward-looking features.

8. Your Privacy Rights

8.1 Universal Rights (Available to All U.S. Users)

You have the right to:

  • Access the personal information we hold about you
  • Correct inaccurate personal information
  • Delete your personal information (subject to legal retention requirements)
  • Receive a portable copy of your information in a common format
  • Withdraw consent for marketing communications anytime

To exercise these rights, email privacy@raiseappraisal.com or use the in-account “Privacy Controls” page. We respond within 45 days (extendable to 90 days for complex requests, with notice).

8.2 California Residents (CCPA / CPRA)

In addition to the universal rights above, California residents have additional rights:

  • The right to know what personal information we collect, use, disclose, and (if applicable) sell or share
  • The right to delete personal information we collected from you
  • The right to correct inaccurate personal information
  • The right to opt out of “sale” or “sharing” of personal information for cross-context behavioral advertising
  • The right to limit the use of “sensitive personal information”
  • The right to non-discrimination for exercising these rights

Sale and Sharing: We do not sell personal information and we do not share personal information for cross-context behavioral advertising as those terms are defined under California law. We do not have a “Do Not Sell or Share My Personal Information” toggle because the underlying activity does not occur.

To exercise California privacy rights or to ask questions, contact us at privacy@raiseappraisal.com or use the DSR Intake Page.

We may verify your identity before responding to your request, typically by confirming details about your account.

Authorized Agents: California residents may designate an authorized agent to make a request on their behalf. We may require written authorization signed by you and proof of agent identity.

8.3 Other State Privacy Laws

If you live in a state with comprehensive privacy legislation (Colorado, Connecticut, Virginia, Utah, Texas, etc.), you generally have similar rights to access, delete, correct, and obtain a copy of your personal information. Contact privacy@raiseappraisal.com to exercise these rights.

9. Security

We implement reasonable administrative, technical, and physical safeguards to protect your information, including:

  • Encryption in transit — all data transmitted to and from our servers uses TLS 1.2 or higher
  • Encryption at rest — databases, file storage, and backups are encrypted using industry-standard methods
  • Access controls — staff access to personal data is role-restricted and logged
  • Multi-factor authentication — required for administrative access
  • Vendor due diligence — sub-processors are evaluated for security practices
  • Incident response plan — formal process for detecting, containing, and notifying about security incidents
  • Annual third-party security review (planned as we approach SOC 2 certification)

No system is perfectly secure. If you become aware of a security issue, please report it to security@raiseappraisal.com.

9.1 Breach Notification

If we experience a security breach affecting your personal information, we will notify you and applicable regulators in accordance with all applicable state and federal breach notification laws — generally within 30 days of discovery (sooner where required).

10. Information About Third Parties in Your Documents

Appraisal documents you upload often contain personal information about other people — most commonly the appraiser (name, license number, contact info). When you upload an appraisal containing third-party information:

  • You confirm you have the right to provide this document to us for the purpose of generating an ROV.
  • We use that information solely to perform the analysis you've requested.
  • We do not contact those third parties or use their information for any other purpose.
  • Where state law gives third parties rights over their data we hold, we will honor those rights to the extent legally required.

If you are an appraiser or other third party whose information appears in our system and you wish to inquire about or request deletion, contact privacy@raiseappraisal.com.

11. Children's Privacy

The Service is not directed to children under 18 and we do not knowingly collect personal information from anyone under 18. If we discover we have collected personal information from a child under 18, we will delete it. If you believe a child under 18 has provided us with personal information, contact us at privacy@raiseappraisal.com.

The Service is also not designed for users under 13. We comply with the Children's Online Privacy Protection Act (COPPA).

12. International Users

The Service is currently offered only to users in the United States. We do not intend to make the Service available to users outside the U.S. If you access the Service from outside the U.S., you do so at your own risk and your information will be processed in the U.S.

13. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will:

  • Update the “Last updated” date at the top of this page
  • Notify active subscribers by email at least 30 days before changes take effect
  • For material changes, ask for affirmative consent where required by law

The current version is always available at raiseappraisal.com/privacy.

14. Contact Us

For privacy questions, requests, or concerns:

Subject line for rights requests
“Privacy Rights Request — [your full name]”
Mail
Malama Funding LLC, Attn: Privacy Team, [address]

We aim to respond to all privacy-related inquiries within 5 business days; formal data subject requests within 45 days.


This Privacy Policy is part of our Terms of Service and operates alongside our Cookie Policy and Sub-Processor List.