VaraX Privacy Policy & Consumer Data Safe Harbor

VaraX operates a proprietary, closed-loop first-party data refinery. Unlike legacy data brokers who scrape public directories or acquire speculative consumer lists, 100% of the operational signals processed by VaraX originate directly from verified first-party transactions across our unified real estate telemetry network.

To deliver real-time underwriting and property risk assessments, our telemetry refinery ingests and evaluates the following functional data layers:

• Continuous Liquid Reserve Telemetry: Liquid balance multipliers, recurring cash-flow regularity scores, and verifiable discretionary buffer percentages.
• Live Rent Execution Momentum: Consecutive on-time payment streak records, automated clearing settlement timestamps, and repair-and-deduct habitability escrow accounts.
• Multimodal Physical Condition Vectors: Computer-vision envelope anomaly classifications (Roof, Foundation, Plumbing, HVAC), move-in baseline photographic records, and verified move-out delta assessments.
• Resident Co-Ownership Holdings: Micro-equity balances in fractional real estate parcels, voluntary round-up contributions, and tenant retention tier advancements.
• Pseudonymized Identifier Tokens: Cryptographically salted SHA-256 tokens isolating consumer identities from underlying analytics records.

To the extent that telemetry reports generated by the VaraX platform (including VaraScore™ continuous underwriting dossiers) constitute a "consumer report" under Section 603 of the Fair Credit Reporting Act (15 U.S.C. § 1681a), VaraX restricts data generation exclusively to authorized commercial subscribers who have certified a statutory permissible purpose under 15 U.S.C. § 1681b.

Permissible purposes include: (a) evaluating a consumer application for a residential lease; (b) extending credit or underwriting a lease guaranty; or (c) explicit written instruction of the consumer to whom the report relates.

In strict accordance with the Gramm-Leach-Bliley Act (GLBA) Safeguards Rule (16 C.F.R. Part 314), VaraX implements comprehensive administrative, technical, and physical safeguards:

Every consumer has the federal statutory right under FCRA § 609 (15 U.S.C. § 1681g) to request a complete disclosure of any consumer reporting file maintained about them by VaraX, as well as the identification of all commercial subscribers who queried their report in the previous 12 months.

If an applicant believes any information on their VaraScore™ dossier is incomplete or inaccurate, they may initiate an expedited dispute. VaraX will conduct a free, statutory reinvestigation within 30 business days pursuant to 15 U.S.C. § 1681i, notify the consumer of results, and correct or expunge inaccurate records immediately.

VaraX retains transactional telemetry records only as long as necessary to fulfill the permissible purpose or satisfy statutory audit requirements:

• Real-Time Ingestion Cache: Ephemeral liquidity telemetry cache automatically purges after 72 hours.
• Underwriting Audit Ledgers: Preserved for 5 years to satisfy statutory compliance obligations under 15 U.S.C. § 1681p.
• Permanent Purge Protocol: Upon expiration of statutory schedules, records undergo irreversible cryptographic key shredding.