PRIVACY & DATA GOVERNANCE POLICY

National Second Chance Network (NSCN) FindSecondChance.com

Effective Date: April 17, 2026 Last Updated: April 18, 2026

1. INTRODUCTION

This Privacy Policy describes how the National Second Chance Network ("NSCN") collects, uses, stores, shares, and protects information obtained through FindSecondChance.com. By accessing or using FindSecondChance.com, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your information as described herein. If you do not agree to the terms of this Privacy Policy, you must discontinue use of the platform immediately. This Privacy Policy applies to all visitors, users, community members, and any other individual or entity that accesses or interacts with FindSecondChance.com in any capacity. This policy should be read in conjunction with the NSCN Terms of Service, which are available on FindSecondChance.com. Throughout this policy, "we," "us," and "our" refer to the operating entity and its operations under the NSCN brand. "You" refers to any individual accessing or using FindSecondChance.com.

2. INFORMATION WE COLLECT

We collect information in several categories depending on how you interact with the platform.

Information you provide directly includes any information you voluntarily submit through FindSecondChance.com. This may include your name, email address, phone number, general location such as your state or metropolitan area, and information about your housing situation, service needs, or personal circumstances that you choose to share through intake forms, service request forms, community membership enrollment, contact forms, or any other submission pathway available on the platform. You are not required to provide any specific information, but certain features or services may not be available if you decline to provide the information requested.

Service-related data includes information generated through the normal operation of the platform and the activity of users and network professionals within the NSCN system. This may include data related to service requests, geographic service areas, service categories, outcomes, timelines, and other operational details generated through platform use. Service-related data may be collected directly from users, from network professionals participating in the NSCN system, or generated automatically through platform operations.

Automatically collected information includes data that is collected passively when you visit FindSecondChance.com. This may include your Internet Protocol (IP) address, browser type and version, device type, operating system, screen resolution, referring URL, pages viewed on the platform, the date and time of your visit, the duration of your visit, click patterns, and data collected through cookies, web beacons, pixel tags, or similar tracking technologies used for website analytics and performance monitoring purposes.

Authorized third-party data includes information obtained through affiliated data brokerage operations operating under valid state licenses, such as lead data acquired through authorized data providers. When such data enters the NSCN system, it is subject to the same use restrictions, sharing limitations, and proprietary research protections described in this Privacy Policy. The handling of authorized third-party data is governed by the consent terms under which it was originally collected by the originating entity and by the terms of this Privacy Policy, whichever imposes the greater restriction on use.

3. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes. To operate, maintain, and improve FindSecondChance.com and the services offered through the platform. To connect you with network professionals based on the information you provide in service requests. To process and manage community membership enrollment. To communicate with you regarding platform updates, resource announcements, service status, and other matters related to your use of the platform. To manage internal operations including intake flow, network capacity planning, and service area coverage. To compile, aggregate, and anonymize service-related data for the purpose of internal research, platform improvement, trend analysis, and the development of proprietary datasets. To comply with applicable legal obligations, regulatory requirements, and lawful governmental requests. To enforce our Terms of Service and protect the rights, safety, and security of the platform, its users, and the public.

4. PROPRIETARY RESEARCH DATA

In the course of operating FindSecondChance.com and coordinating services through the NSCN network, the operating entity collects and compiles service-related data that is used to develop proprietary research datasets and analytical products. All proprietary research data is owned exclusively by the entity operating FindSecondChance.com. All proprietary research intelligence, datasets, indexes, registries, and analytical products developed from service-related data collected through FindSecondChance.com or through the operational activity of the NSCN network are the exclusive intellectual property of the operating entity and shall remain so regardless of any change in branding, operating name, or public-facing identity.

Proprietary research data is compiled from aggregated and anonymized service-related activity across the platform and does not contain personally identifying information in its published or distributed form.

The operating entity may use proprietary research data for internal analysis, platform development, trend monitoring, and to support the mission of improving outcomes for individuals navigating systemic barriers in housing and related areas. The operating entity may also make proprietary research data available to qualifying external organizations at its sole discretion. Qualifying organizations may include but are not limited to academic researchers, legal advocacy organizations, fair housing attorneys, nonprofit entities, housing policy organizations, legislative bodies, and governmental agencies whose work supports the advancement of equitable housing access and the reduction of systemic barriers.

The operating entity reserves the right to sell, license, sublicense, publish, distribute, or otherwise make available proprietary research data and intelligence products to qualifying organizations under terms determined solely by the operating entity. The availability of proprietary research data to external organizations does not create any obligation on the part of the operating entity to provide data to any specific organization or for any specific purpose. The operating entity determines at its sole discretion which organizations qualify, the format and scope of data provided, and the commercial or non-commercial terms under which it is made available.

The operating entity may also route authorized third-party lead data acquired through licensed data brokerage affiliates to NSCN-verified professionals and aligned organizations that have been vetted by the operating entity and that operate in support of the second-chance economy. Authorized third-party lead data is never routed to any entity appearing on the exclusion list described below. All routing of authorized third-party lead data is governed by the consent terms of the originating collection and by this Privacy Policy.

Proprietary research data is never sold, licensed, shared, or made available to debt collectors, tenant screening companies, consumer reporting agencies, landlords or property management companies seeking to use the data to deny housing, data brokers, lead generation companies, skip tracing services, or any entity whose purpose is to financially exploit, commercially target, or further disadvantage the individuals or communities documented in the data. This restriction applies regardless of the amount offered or the stated purpose of the requesting entity. The operating entity reserves the right to refuse any request for data access that it determines, in its sole discretion, does not align with the mission of supporting equitable housing outcomes and the second-chance economy.

5. WHAT WE DO NOT DO WITH YOUR PERSONAL INFORMATION

Your personal identifying information, which includes your name, email address, phone number, and any other information that directly identifies you as an individual, is handled in accordance with the following commitments. Your personal identifying information collected through FindSecondChance.com is never sold, leased, rented, licensed, or traded to any third party for marketing purposes, advertising purposes, unsolicited commercial contact, or any purpose that does not directly serve your stated housing, legal, financial, or service need. When your information is shared with an NSCN-verified professional or an aligned partner organization, it is shared solely for the purpose of fulfilling the service request you initiated or connecting you with a resource relevant to your stated need. Your personal identifying information is never entered into any lead generation system, lead distribution platform, or data marketplace. Your personal identifying information is never distributed to multiple service providers simultaneously in exchange for referral commissions, referral fees, or any other form of compensation tied to the distribution of your contact information. When you submit a service request through FindSecondChance.com, your information is directed to the specific network professional or intake pathway associated with your request and is not broadcast, auctioned, or distributed to competing providers.

6. HOW WE SHARE YOUR INFORMATION

Beyond the proprietary research data framework described in Section 4 of this policy, we share your information only in the following limited circumstances.

With network professionals. When you submit a service request, the information you provide in that request is shared with the network professional or intake pathway associated with your request so that they can respond to and fulfill your request.

With aligned partners. In limited circumstances, the operating entity may share service request data or authorized third-party lead data with vetted partner organizations that operate in support of the second-chance economy. Aligned partners may include legal aid organizations, fair housing advocates, housing counseling agencies, nonprofit service providers, and other entities whose mission supports equitable housing access. Aligned partners are prohibited from using shared data for debt collection, tenant screening, consumer reporting, unsolicited marketing, or any purpose that would financially exploit or further disadvantage the individuals described in the data. The operating entity determines at its sole discretion which organizations qualify as aligned partners.

With service providers. We may share your information with third-party service providers who perform essential technical and operational functions on our behalf, such as website hosting, server maintenance, email delivery, analytics, and platform security. These service providers are contractually obligated to use your information solely for the purpose of performing the specific service we have engaged them to provide and are prohibited from using your information for any other purpose.

When required by law. We may disclose your information when we believe in good faith that disclosure is required by applicable law, regulation, legal process, subpoena, court order, or enforceable governmental request. We may also disclose information when we believe disclosure is necessary to protect the rights, property, or safety of the operating entity, our users, or the public, or to detect, prevent, or address fraud, security issues, or technical problems.

In connection with a business transfer. In the event that the operating entity undergoes a merger, acquisition, reorganization, dissolution, asset sale, or similar transaction, your information may be transferred as part of that transaction. In such a case, we will make reasonable efforts to ensure that the receiving entity honors the commitments made in this Privacy Policy or provides you with notice and an opportunity to opt out of the transfer of your information. Notwithstanding the foregoing, all proprietary research data, datasets, indexes, registries, and intelligence products shall remain the exclusive property of the operating entity and shall transfer only as an asset of the operating entity in any such transaction.

7. IDENTIFIED DATA FOR LEGAL AND ADVOCACY PURPOSES

In limited circumstances where a qualifying legal entity such as a fair housing attorney, legal advocacy organization, or governmental enforcement body requires identified information to support a specific legal action, complaint, investigation, or enforcement proceeding such as a HUD complaint, fair housing claim, disparate impact analysis, or class action, the operating entity may at its sole discretion provide identified data. Before any identified data is released under this provision, the operating entity will make reasonable efforts to notify the individual community members involved and to obtain their participation or consent where practicable. Release of identified data under this provision is not automatic, is evaluated on a case-by-case basis, and is reserved exclusively for legal, advocacy, or enforcement purposes that serve the interests of the affected community members. The operating entity shall not release identified data under this provision to any entity that does not meet the qualifying criteria described herein.

8. COOKIES AND TRACKING TECHNOLOGIES

FindSecondChance.com uses cookies and similar tracking technologies to collect automatically generated information as described in Section 2 of this policy. Cookies are small text files placed on your device by a website that store certain information about your browsing activity. We use cookies for the following purposes: to analyze website traffic patterns and visitor behavior for the purpose of improving the platform, to remember your preferences and settings to enhance your experience on the platform, to monitor platform performance, load times, and error rates, and to support analytics services provided by third-party tools. You may manage your cookie preferences through your browser settings. Most browsers allow you to block or delete cookies, but doing so may affect the functionality of certain features on FindSecondChance.com. Your continued use of the platform without modifying your cookie settings constitutes your consent to the use of cookies as described in this policy.

9. DATA RETENTION

We retain your personal identifying information for as long as reasonably necessary to fulfill the purposes described in this policy, to provide services you have requested, to maintain your community membership, to comply with applicable legal and regulatory obligations, and to resolve disputes. When your personal identifying information is no longer needed for any of these purposes, we will delete or anonymize it within a reasonable timeframe.

Service-related data and proprietary research data is retained indefinitely as a permanent operational and research asset of the operating entity. This data is anonymized and aggregated and does not contain personally identifying information in its retained form. The indefinite retention of proprietary research data is necessary to maintain the integrity, continuity, and historical value of the operating entity's research intelligence products and to support ongoing analysis of systemic patterns over time.

If you wish to request the deletion of your personal identifying information, you may contact us at the email address provided in Section 16 of this policy. We will process your request within a reasonable timeframe, subject to any legal retention requirements that may apply. Please note that the deletion of your personal identifying information does not affect any anonymized or aggregated data that has already been incorporated into proprietary research datasets owned by the operating entity, as such data is no longer personally identifiable and constitutes the intellectual property of the operating entity.

10. DATA SECURITY

We implement reasonable administrative, technical, physical, and organizational security measures designed to protect personal information and all platform data from unauthorized access, disclosure, alteration, destruction, loss, or misuse. These measures include but are not limited to the use of encryption technologies for data in transit, access controls limiting data access to authorized personnel, regular monitoring of platform systems for vulnerabilities, and secure storage practices for retained data. However, no method of electronic transmission over the internet or method of electronic data storage is completely secure. While we strive to protect your information using commercially reasonable measures, we cannot guarantee the absolute security of any information transmitted to or stored on FindSecondChance.com. You acknowledge that you transmit information to the platform at your own risk.

11. YOUR RIGHTS

Depending on your state of residence, you may have certain rights regarding your personal information under applicable privacy laws including but not limited to the California Consumer Privacy Act (CCPA), the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (CPA), the Connecticut Data Privacy Act (CTDPA), and similar state privacy statutes. These rights may include the right to know what personal information we have collected about you, the right to access your personal information, the right to request correction of inaccurate personal information, the right to request deletion of your personal information subject to applicable exceptions, the right to opt out of the sale of personal information, and the right to not be discriminated against for exercising your privacy rights.

As described in this policy, we do not sell personal identifying information for marketing, advertising, or unsolicited commercial purposes. Anonymized and aggregated service-related data that has been incorporated into proprietary research datasets owned by the operating entity does not constitute personal information under applicable privacy laws and is not subject to individual opt-out requests. Proprietary research datasets are the intellectual property of the operating entity and are exempt from individual deletion requests once data has been anonymized and aggregated.

To exercise any of your privacy rights, contact us at nscn@findsecondchance.com. We will respond to verifiable requests within the timeframe required by applicable law, generally within forty-five (45) days of receipt. We may request additional information from you to verify your identity before processing your request.

12. DO NOT TRACK SIGNALS

Some web browsers transmit "Do Not Track" (DNT) signals to the websites you visit. There is currently no universally accepted standard for how websites should respond to DNT signals. At this time, FindSecondChance.com does not alter its data collection or use practices in response to DNT signals. If a uniform standard for responding to DNT signals is established in the future, we will review and update this policy accordingly.

13. CHILDREN'S PRIVACY

FindSecondChance.com is not directed to individuals under the age of eighteen (18). We do not knowingly collect, solicit, or maintain personal information from anyone under the age of eighteen. If we become aware that we have collected personal information from a minor, we will take prompt steps to delete that information from our systems. If you believe that a minor has provided personal information to us through the platform, please contact us immediately at the email address provided in Section 16 of this policy.

14. THIRD-PARTY LINKS

FindSecondChance.com may contain links to websites, platforms, applications, or resources operated by third parties. These links are provided for your convenience and do not signify our endorsement of, affiliation with, or responsibility for the content, privacy practices, or terms of use of those third-party sites. We encourage you to review the privacy policies of any third-party website you visit, as their practices may differ from ours. The operating entity is not responsible for the privacy practices or the content of any third-party website.

15. CHANGES TO THIS POLICY

We reserve the right to update, revise, or modify this Privacy Policy at any time and for any reason at our sole discretion. When changes are made, the revised Privacy Policy will be posted on FindSecondChance.com with an updated "Last Updated" date. It is your responsibility to review this policy periodically. Your continued use of FindSecondChance.com after any changes are posted constitutes your acceptance of the updated Privacy Policy. If you do not agree to any revised terms, your sole remedy is to discontinue use of the platform.

SECTION 16 — PROPRIETARY TOOLS DATA COLLECTION

When you access or use any NSCN proprietary tool, including but not limited to the PHA Policy Monitor, SOI Law Tracker, Eviction Filing Index, Voucher Funding Tracker, Voucher Success Rate Monitor, Manual Review Accelerator, Residency Profile Architect, Income Authority Engine, or the NSCN Quarterly Report, we collect standard analytics data as described in the Automatically Collected Information portion of Section 2 of this Privacy Policy. NSCN proprietary tools are designed as reference and educational resources. No personal information is captured, stored, or transmitted when you view, download, or use templates, worksheets, checklists, or other documents provided through NSCN tools. Any information you enter into a downloadable template, worksheet, or checklist remains on your own device and is not transmitted to NSCN or any third party through the platform. If you provide your email address to join a tool waitlist, receive tool updates, or subscribe to a tool notification list, your email address will be used solely for that stated purpose. Email addresses collected through tool waitlists or notification lists are never sold, shared, rented, or distributed to any third party for marketing, advertising, or any other purpose.

SECTION 17 — PARTNERSHIP PIPELINE DATA

NSCN maintains partnership pipeline databases containing contact information for organizations that serve voucher holders, second-chance renters, and related populations. The information in these databases — including organization names, staff names, titles, phone numbers, email addresses, and website URLs — is sourced exclusively from publicly available records, including government agency websites, HUD databases, organizational websites, and public directories. Inclusion in an NSCN partnership pipeline database does not indicate that the organization has a formal relationship with NSCN unless the organization has been designated as an NSCN Verified Partner. Organizations or individuals who appear in an NSCN partnership database may request correction or removal of their information by contacting NSCN at nscn@findsecondchance.com or through FindSecondChance.com/contact-us. NSCN will process correction or removal requests within ten (10) business days of receipt.

18. CONTACT

National Second Chance Network (NSCN) FindSecondChance.com Email: nscn@findsecondchance.com