Privacy Policy

Club 720 Privacy Policy

Effective Date: August 21, 2026
Last Updated: August 21, 2026

Club 720® is committed to protecting the privacy, security, and appropriate use of personal information.

This Privacy Policy explains how Club 720 collects, uses, stores, shares, and protects information when you use our website, mobile application, platform, programs, marketplace, coaching tools, and related services.

Our approach is guided by a simple principle:

People, organizations, systems, and technology should have access only to the information reasonably necessary to perform an authorized function.

This Privacy Policy applies to Club 720 consumer-facing services in the United States. Additional notices may apply to particular programs, services, jurisdictions, or relationships.

1. Information We Collect

The information we collect depends on how you use Club 720 and which services you choose to use.

Personal and Contact Information

We may collect information such as:

• Name;

• Mailing address;

• Email address;

• Telephone number;

• Date of birth or age;

• Account information;

• Communication preferences; and

• Other information you voluntarily provide.

Household, Housing, and Demographic Information

We may collect information that helps us understand your housing needs and connect you with appropriate resources, including:

• Household size;

• Household income;

• Housing goals;

• Current housing situation;

• Desired housing type;

• Preferred location;

• Estimated purchase or rental price range;

• Employment-related information;

• Race or ethnicity where voluntarily provided and appropriate;

• Gender where voluntarily provided and appropriate; and

• Other demographic or household information.

Demographic information associated with an identifiable user is treated as personal information. We do not assume that demographic information is anonymous simply because it describes a category or characteristic.

Financial and Housing-Readiness Information

Depending on the services you choose, Club 720 may collect information related to your financial or housing-readiness circumstances, such as:

• Income;

• Estimated savings;

• Housing expenses;

• Debt or financial obligations;

• Cash-to-close readiness;

• Mortgage or financing needs;

• Program eligibility information; and

• Other financial information you choose to provide.

Consumer Credit Information

Certain Club 720 services may allow eligible consumers to access soft-pull credit information or credit-readiness tools.

Consumer credit information is treated as sensitive information and is subject to additional access, contractual, compliance, and security requirements.

Club 720 has undergone compliance reviews associated with its authorization to access consumer soft-pull credit information through national consumer reporting agencies.

Access to consumer credit information is limited to authorized purposes, systems, workflows, and users.

Program, Referral, and Marketplace Information

We may collect information about:

• Programs you explore or apply for;

• Services you request;

• Partners you select or are referred to;

• Referral status;

• Housing professionals with whom you choose to connect;

• Housing opportunities you express interest in; and

• Progress through your housing journey.

Device and Usage Information

When you use our website, mobile application, or platform, we may automatically collect certain technical information, including:

• IP address;

• Browser type;

• Device type;

• Operating system;

• Login activity;

• Pages or features used;

• Dates and times of access; and

• Other information used to operate, secure, and improve our services.

Communications

We may retain information you provide when you:

• Contact Club 720;

• Communicate with customer support;

• Complete a form;

• Participate in a survey;

• Attend an event;

• Communicate through the platform; or

• Otherwise interact with us.

2. How We Use Information

We may use information to:

• Create and maintain your Club 720 account;

• Help you identify and pursue housing goals;

• Provide housing-readiness tools;

• Connect you with programs, products, and participating professionals;

• Facilitate referrals you request or authorize;

• Provide consumer support;

• Communicate with you about your account or services;

• Provide relevant educational information and resources;

• Operate and improve the Club 720 platform;

• Understand community-level housing demand;

• Evaluate program utilization and marketplace performance;

• Maintain security and prevent misuse;

• Troubleshoot technology;

• Meet contractual obligations;

• Comply with legal and regulatory requirements; and

• Improve the housing services and resources available through Club 720.

We seek to collect and use only the information reasonably necessary for the applicable purpose.

3. Consumer Intelligence and Community Intelligence

Club 720 distinguishes between Consumer Intelligence and Community Intelligence.

Consumer Intelligence

Consumer Intelligence relates to an identifiable individual’s housing journey, goals, readiness, financial circumstances, interactions, referrals, or services.

Community Intelligence

Community Intelligence helps communities understand broader housing-market conditions and may include information such as:

• Number of households seeking housing;

• Housing types consumers are seeking;

• Price and rent ranges;

• Financing barriers;

• Cash-to-close challenges;

• Program utilization;

• Geographic demand;

• Marketplace gaps;

• Builder and lender participation; and

• Housing supply and production opportunities.

Whenever practical, Club 720 uses aggregated, de-identified, or community-level information to provide Community Intelligence.

A local government or community does not automatically receive unrestricted access to an individual consumer’s financial information simply because the community sponsors or participates in a Club 720 program or activation.

For example, a community may need to know that a significant number of households are experiencing a cash-to-close barrier.

It generally does not need the individual financial records of every household experiencing that barrier.

4. Who May Access Individual Consumer Information

Access to individual consumer information is based on authorized purpose, role, and need.

Depending on the service being provided, information may be accessible to the following parties.

You

You may access information associated with your own Club 720 account, subject to available platform functionality.

Authorized Club 720 Personnel

Authorized Club 720 personnel may access information when reasonably necessary to perform functions such as:

• Consumer support;

• Referral assistance;

• Platform administration;

• Compliance;

• Security;

• Troubleshooting; and

• Other authorized operational responsibilities.

Access is intended to be limited to the information necessary for the function being performed.

Professionals or Service Providers You Choose to Work With

You may choose to connect with participating professionals or organizations, such as:

• Lenders;

• HUD-certified housing counselors;

• Real estate professionals;

• Program administrators;

• Housing providers; or

• Other participating service providers.

When information is necessary to provide a service you request or authorize, appropriate information may be shared through an approved workflow.

Participation in Club 720 does not provide a professional or organization with unrestricted access to all Club 720 consumers or all information contained within the platform.

Technology and Data Service Providers

We may use vendors and technology providers to operate or support our services.

These organizations may process information on our behalf when reasonably necessary to provide their services and are subject to applicable contractual, privacy, security, and data-use requirements.

5. Community and Government Access

Communities using Club 720 generally receive housing-system intelligence rather than unrestricted individual consumer financial records.

Community users may receive information such as:

• Aggregated demand;

• Housing preferences;

• Price ranges;

• Financing barriers;

• Program usage;

• Market trends;

• Partner activity;

• Housing production information; and

• Other community-level indicators.

If a specific use case requires individual consumer information to be disclosed to a government or community partner, the disclosure must have an authorized purpose and must be consistent with applicable consent, privacy, contractual, and legal requirements.

6. Artificial Intelligence

Club 720 uses artificial intelligence in certain tools and services.

The fact that Club 720 uses AI does not mean that an AI system automatically receives access to all information held by Club 720.

Different tools serve different purposes and may have different levels of access.

Club 720 seeks to apply data-minimization principles when using AI:

If an AI function does not need a piece of information to perform its authorized purpose, it should not receive access to that information.

Community-facing tools such as H.O.M.E. Intelligence are intended primarily to work with:

• Public information;

• Community-level information;

• Market information;

• Program and policy information; and

• Information deliberately provided for an authorized community-analysis purpose.

These tools are not intended to serve as repositories for confidential individual consumer records unless a specific workflow has been expressly approved for that purpose.

AI may assist with navigation, analysis, organization, communication, or decision support.

AI does not independently make final consequential decisions such as:

• Mortgage lending decisions;

• Credit decisions;

• Housing eligibility determinations;

• Funding commitments;

• Legal determinations;

• Procurement decisions;

• Public policy decisions; or

• Final development decisions.

Those decisions remain with the people and organizations authorized to make them.

7. Data Minimization

Club 720 seeks to collect, use, and disclose only information reasonably necessary for an authorized purpose.

When designing new services, workflows, integrations, or technology features, we consider questions such as:

• What information is actually needed?

• Can the objective be achieved with less sensitive information?

• Can aggregated or de-identified information be used instead?

• Who needs access?

• How long does the information need to be retained?

Possessing information does not, by itself, create a reason to access or disclose it.

8. Data Storage and Security

Club 720 uses administrative, technical, and organizational safeguards designed to protect information from unauthorized access, disclosure, alteration, misuse, or loss.

Club 720’s platform environment is hosted within Microsoft Azure regions located in the United States.

Our current technical environment includes:

• Encryption of production database information at rest;

• HTTPS-secured application traffic in transit;

• Access controls for sensitive information;

• Database backup and recovery practices;

• Security and incident-response procedures; and

• Administrative controls intended to limit unauthorized access.

Security practices evolve as technology, risk, and regulatory requirements change.

No technology environment can guarantee absolute security, but Club 720 continuously works to strengthen its controls and reduce risk.

9. Security and Compliance Program

Club 720 has maintained documented data protection, disaster recovery, access-control, backup, and incident-response practices for several years.

Club 720 has also undergone compliance reviews associated with authorization by TransUnion and, previously, Equifax to access and provide consumers with soft-pull credit information.

Those reviews are specific to the applicable consumer-credit relationships and should not be interpreted as SOC 2 certification.

Club 720 is currently expanding and formalizing its broader security and privacy program through Vanta.

This initiative includes:

• SOC 2 Type II readiness and independent audit;

• U.S. data privacy compliance;

• Continuous security-control monitoring;

• Formal policy and control management;

• Security implementation support; and

• Independent penetration testing.

Club 720 does not represent itself as SOC 2 certified or attested until the applicable independent audit has been completed successfully.

Appropriate security and compliance information may be made available to institutional clients and partners through Club 720’s security and trust process.

10. Data Retention

Club 720 retains information only as reasonably necessary for purposes such as:

• Providing services;

• Maintaining consumer accounts;

• Fulfilling referrals;

• Program administration;

• Contractual obligations;

• Compliance;

• Security;

• Audit requirements;

• Legal requirements; and

• Other legitimate business purposes.

Club 720 is formalizing a detailed retention schedule that assigns retention and disposition requirements by data category.

When information is no longer required, it may be:

• Deleted;

• De-identified;

• Aggregated;

• Archived; or

• Otherwise disposed of in accordance with applicable legal, contractual, security, and operational requirements.

Certain information may need to be retained even after an account is closed or a deletion request is made when retention is required or permitted for legal, contractual, fraud-prevention, security, compliance, or other legitimate purposes.

11. Your Privacy Choices and Rights

Depending on where you live and applicable law, you may have rights concerning your personal information.

These may include the ability to:

• Request information about personal information we maintain about you;

• Request access to certain personal information;

• Request correction of inaccurate information;

• Request deletion of certain information;

• Request limitation of certain uses where applicable;

• Opt out of certain marketing communications; and

• Exercise other rights available under applicable privacy law.

Certain requests may be subject to exceptions or limitations under applicable law or contractual requirements.

We may need to verify your identity before completing a privacy request.

Club 720 will not discriminate against a consumer for exercising a privacy right provided by applicable law.

To submit a privacy request, please use Club 720’s designated privacy request process or contact us using the information below.

12. Marketing Communications

You may opt out of promotional email communications by using the unsubscribe mechanism contained in those communications or by contacting Club 720.

Even if you opt out of marketing communications, we may continue to send transactional or service-related communications that are necessary to operate your account or provide services you requested.

13. Service Providers and Third Parties

Club 720 may work with third parties that support services such as:

• Cloud hosting;

• Communications;

• Payment processing;

• Consumer credit services;

• Analytics;

• Customer support;

• Security;

• Software development;

• Compliance;

• Professional services; and

• Other platform operations.

Third-party access should be limited to the information reasonably necessary to provide the applicable service.

Club 720 evaluates third-party relationships according to the nature of the service and the sensitivity of the information involved.

14. Legal and Required Disclosures

Club 720 may disclose information where reasonably necessary to:

• Comply with applicable law;

• Respond to a valid court order, subpoena, or governmental request;

• Protect the rights, safety, or property of Club 720, our users, or others;

• Investigate fraud, misuse, or security incidents;

• Enforce agreements or policies; or

• Meet another lawful obligation.

Where appropriate and legally permitted, Club 720 seeks to limit disclosures to information reasonably necessary for the applicable purpose.

15. Business Transactions

If Club 720 participates in a merger, acquisition, financing, restructuring, sale of assets, or other business transaction, information may be transferred as part of that transaction.

Any successor organization receiving personal information would remain subject to applicable privacy and legal obligations.

16. Children’s Privacy

Club 720’s consumer services are not directed to children under 13.

We do not knowingly collect personal information directly from children under 13 through services intended for the general public.

If we learn that personal information from a child under 13 has been collected inappropriately, we will take reasonable steps to address the information in accordance with applicable law.

17. U.S. Operations and International Privacy Frameworks

Club 720’s current consumer and community operations are focused in the United States.

Club 720 does not currently represent itself as compliant with the European Union General Data Protection Regulation (GDPR).

If Club 720 expands its operations in a way that makes GDPR or another international privacy framework applicable, we will evaluate and implement applicable legal, contractual, operational, and technical requirements before representing compliance with that framework.

18. Account Closure and Community Program Changes

Your Club 720 account is generally separate from a local government’s decision to continue or discontinue a community relationship with Club 720.

If a community ends its Club 720 engagement:

• Your Club 720 account does not necessarily terminate;

• Your personal information is not automatically transferred to that community;

• Community-specific programs or services may change or become unavailable;

• Community access to managed dashboards or reporting may end; and

• Club 720 will continue to handle information according to this Privacy Policy, applicable terms, and legal requirements.

19. Changes to This Privacy Policy

Club 720 may update this Privacy Policy as our technology, services, privacy practices, security program, or legal obligations evolve.

When we make material changes, we will update the effective date and provide additional notice when appropriate.

We encourage users to review this Privacy Policy periodically.

20. Contact Us

If you have questions about this Privacy Policy, Club 720’s privacy practices, or your personal information, please contact us.

Club 720
Privacy Contact: [email protected]

For security-related inquiries from institutional clients or partners, Club 720 may also provide additional documentation through its Security & Trust process.

Our Privacy Principle

Club 720’s approach to information can be summarized simply:

Protect the data.
Collect only what is needed.
Limit access by purpose.
Separate consumer and community intelligence.
Use aggregated information whenever practical.
Respect the sensitivity of consumer credit information.
Keep humans accountable for consequential decisions.
Test and continuously improve our safeguards.

The trust consumers place in Club 720 is not incidental to our work.

It is an operating requirement.