Privacy Policy

Custom Seal Property Investments LLC (“CSPI,” “we,” “us,” or “our”) operates the property management platform at customsealproperty.com (the “Platform”). This Privacy Policy describes how we collect, use, store, share, and protect information when you use our Platform as a tenant, applicant, property owner, or visitor.

By using the Platform you agree to this Privacy Policy. If you do not agree, please do not use the Platform.

1. Information We Collect

1.1 Information You Provide

• Rental Applications: Full name, date of birth, Social Security Number (SSN), current and prior addresses, employment and income information, rental history, and consent to background and credit checks.
• Tenant Portal Registration: Name, email address, password, and phone number.
• Maintenance Requests: Unit address, description of issue, and any photos you upload.
• Rent Payments: Bank account details (ACH) or payment card information processed securely through Stripe. CSPI does not store full card or bank account numbers.
• Tour Requests: Name, email, phone, current address, desired move-in date, household size, gross monthly income, and pet/smoking disclosures.
• Lease Documents: Electronic signature data and lease agreement contents.
• Communications: Any messages, emails, or inquiries you send to us.

1.2 Information Collected Automatically

• IP address, browser type, device type, and operating system.
• Pages visited, time spent on pages, and referring URLs.
• Session cookies and authentication tokens necessary to keep you logged in.

1.3 Information from Third Parties

• Background & Credit Checks: We use third-party screening services (such as Checkr or Certn) to obtain background check and credit report data for rental applicants, with your consent.
• Bank Verification: We use Plaid to verify bank accounts for ACH payments. Plaid’s privacy policy is available at plaid.com/legal.
• SMS Communications: We use Twilio to deliver text message notifications. Message and data rates may apply.

2. How We Use Your Information

• Process rental applications and communicate decisions.
• Execute and manage lease agreements, including electronic signatures.
• Collect rent payments and maintain payment ledger records.
• Send rent reminders, late notices, maintenance updates, and compliance alerts via email and SMS.
• Schedule and manage property inspections and maintenance requests.
• Screen applicants for tenancy using lawful background and credit check procedures.
• Comply with Philadelphia landlord-tenant law, Pennsylvania state law, and applicable federal law, including Fair Housing Act requirements.
• Improve platform functionality, troubleshoot issues, and ensure security.
• Respond to your inquiries and provide customer support.

3. Legal Basis for Processing (where applicable)

We process your personal information on the following bases: (a) performance of a contract (lease agreement or application); (b) compliance with legal obligations; (c) your explicit consent (background checks, bank verification); and (d) our legitimate interests in operating a property management business, where those interests do not override your rights.

4. SMS / Text Message Communications

10DLC By providing your mobile phone number and opting in, you consent to receive text messages from CSPI regarding rent reminders, maintenance updates, lease notices, and account alerts. Message frequency varies. Message and data rates may apply. Reply STOP to opt out at any time. Reply HELP for help. Opting out of SMS will not affect your legal rights or obligations under your lease.

We comply with the Telephone Consumer Protection Act (TCPA) and CTIA messaging guidelines. We do not share your mobile number with third parties for their marketing purposes.

5. Sharing of Information

We do not sell your personal information. We share information only as follows:

• Service Providers: Stripe (payments), Plaid (bank verification), Twilio (SMS), SendGrid (email), Checkr/Certn (background checks), Cloudflare (security), and our cloud hosting provider. Each is bound by confidentiality and data protection obligations.
• Property Owners: Relevant tenancy and payment information may be shared with property owners whose units you rent or have applied for.
• Legal Requirements: We may disclose information when required by law, court order, or government authority, or to protect the rights, safety, and property of CSPI, our tenants, and the public.
• Business Transfers: If CSPI is involved in a merger, acquisition, or asset sale, your information may be transferred. We will notify you before your information becomes subject to a different privacy policy.

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this policy, comply with legal obligations, resolve disputes, and enforce our agreements. Rental application data for denied applicants is retained for a minimum of two (2) years under Pennsylvania and federal fair housing record-keeping requirements. Lease and payment records are retained for a minimum of seven (7) years for accounting and legal compliance purposes.

7. Security

We implement industry-standard security measures including TLS encryption for data in transit, bcrypt password hashing, TOTP multi-factor authentication for administrative accounts, rate limiting, and routine security audits. No method of transmission over the internet is 100% secure, and we cannot guarantee absolute security. We have adopted a written Information Security Policy and TLS Certificate Policy consistent with our operational requirements.

8. Your Rights

Depending on your location and applicable law, you may have the right to:

• Access the personal information we hold about you.
• Request correction of inaccurate information.
• Request deletion of your personal information (subject to legal retention requirements).
• Opt out of SMS communications by replying STOP.
• Lodge a complaint with a supervisory authority.

To exercise any of these rights, contact us at customsealproperty@gmail.com.

9. Children’s Privacy

The Platform is not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us immediately.

10. Fair Housing

CSPI complies with the Fair Housing Act, the Pennsylvania Human Relations Act, and the Philadelphia Fair Practices Ordinance. We do not discriminate on the basis of race, color, national origin, religion, sex, familial status, disability, sexual orientation, gender identity, source of income, or any other protected class in the rental of housing or provision of services.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated policy on this page with a revised effective date. Material changes will be communicated to active tenants by email. Your continued use of the Platform after changes become effective constitutes acceptance of the updated policy.

12. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact:

• Custom Seal Property Investments LLC
• Robert A. Mokshefsky, d/b/a Custom Seal Property Investments LLC
• Philadelphia, Pennsylvania
• Email: customsealproperty@gmail.com
• Phone: (267) 407-3716
• Portal: customsealproperty.com