Compliance Policy

1N599 Labs is committed to full compliance with the Fair Housing Act (42 U.S.C. §§ 3601–3619), the Civil Rights Act of 1866, and all state fair housing laws. The Platform is designed to promote equal opportunity in housing and expressly prohibits discrimination in any aspect of a real estate transaction on the basis of:

* Protected in Texas and/or certain jurisdictions

User Obligations: All agents, brokers, landlords, and sellers using the Platform agree to comply with fair housing laws in all listings, communications, and transactions. Discriminatory listings will be removed immediately without notice.

AI Fairness: 1N599 Labs actively audits its AI systems for disparate impact across protected classes. We do not use race, color, national origin, religion, sex, disability, or familial status as factors in pricing algorithms or recommendation systems.

Reporting: Fair housing violations may be reported to the U.S. Department of Housing and Urban Development (HUD) at 1-800-669-9777 orwww.hud.gov, or to our compliance team at compliance@elara.ai.

Where the Platform facilitates mortgage or financing inquiries, 1N599 Labs and its Loan Officer partners comply with the Equal Credit Opportunity Act (15 U.S.C. § 1691), which prohibits credit discrimination based on race, color, religion, national origin, sex, marital status, age (if 18+), or receipt of public assistance.

• Adverse action notices are provided as required within required timeframes
• Credit scoring and pre-qualification tools are audited for ECOA compliance
• All Loan Officer partners using the Platform must maintain valid NMLS credentials and comply with ECOA

The Platform is designed to comply with the Real Estate Settlement Procedures Act (12 U.S.C. § 2601) (RESPA). 1N599 Labs:

• Does not accept or pay referral fees, kickbacks, or unearned fees in connection with federally related mortgage loans
• Does not require use of any affiliated business arrangement (AfBA) as a condition of closing
• Discloses any business relationships between settlement service providers where required
• Provides required disclosures (Loan Estimate, Closing Disclosure) through integrated Loan Officer workflows

Users: Real estate professionals using the Platform agree not to accept or pay kickbacks or referral fees that violate RESPA. Any suspected RESPA violations should be reported to compliance@elara.ai.

1N599 Labs maintains an Anti-Money Laundering program designed to comply with the Bank Secrecy Act (BSA), FinCEN regulations, and applicable OFAC sanctions.

• Identity Verification (KYC): Users are subject to identity verification before accessing certain financial or transactional features
• Sanctions Screening: User identities are screened against OFAC Specially Designated Nationals (SDN) list and other applicable sanctions lists
• Suspicious Activity: We reserve the right to report suspicious activity to FinCEN or other relevant authorities as required by law
• Cash Transaction Reporting: Transactions involving large cash amounts that trigger reporting obligations will be reported as required
• No Facilitation of Illegal Transactions: The Platform may not be used to facilitate money laundering, fraud, or the proceeds of illegal activity

To the extent 1N599 Labs handles non-public personal financial information (NPI) in connection with financing features, we maintain a comprehensive information security program in compliance with the Gramm-Leach-Bliley Act and FTC Safeguards Rule:

• Designation of a qualified Information Security Officer
• Risk assessment and penetration testing program
• AES-256 encryption of all NPI at rest; TLS 1.3 in transit
• Multi-factor authentication for all staff with NPI access
• Vendor due diligence and data processing agreements with all service providers handling NPI
• Incident response plan with customer notification procedures

Where the Platform integrates background check or credit reporting services, 1N599 Labscomplies with the Fair Credit Reporting Act (15 U.S.C. § 1681):

• Background checks are only conducted with explicit written consent from the subject
• Adverse action procedures are followed when a background check negatively affects a decision
• Dispute resolution processes are in place for incorrect background check information
• Consumer reports are used only for permissible purposes under FCRA

1N599 Labs is a technology platform, not a licensed real estate broker in Texas. However, all agents and brokers using the Platform must maintain a valid Texas real estate license issued by the Texas Real Estate Commission (TREC) and comply with:

• Texas Occupations Code, Chapter 1101 (Real Estate License Act)
• TREC Rules (22 TAC, Chapter 535)
• Texas Property Code disclosure requirements
• NAR Code of Ethics (for NAR members)

1N599 Labs reserves the right to verify license status and suspend accounts where a license has lapsed, been revoked, or is under investigation.

1N599 Labs is committed to responsible AI use in real estate. Our AI governance framework:

• Transparency: Users are informed when AI generates content, recommendations, or decisions
• Human Oversight: All AI-assisted decisions affecting users can be reviewed by a human upon request
• Fairness Audits: AI models are regularly tested for disparate impact across protected classes
• No Discriminatory Inputs: Race, color, national origin, religion, sex, disability, and familial status are not inputs to any pricing, valuation, or matching algorithm
• CFPB Guidance: We follow Consumer Financial Protection Bureau guidance on algorithmic models in credit and housing decisions
• Explainability: We maintain documentation of AI model design, training data, and decision logic sufficient for regulatory review

Electronic signatures facilitated through the Platform comply with the Electronic Signatures in Global and National Commerce Act (E-SIGN) and the Uniform Electronic Transactions Act (UETA) as adopted in Texas. Documents executed electronically through the Platform have the same legal force as paper originals.

Users consent to receiving disclosures, agreements, and notices electronically as part of the account registration process. This consent may be withdrawn (which may affect your ability to use certain features) by contacting support@elara.ai.

1N599 Labs is committed to making the Platform accessible to persons with disabilities in compliance with the Americans with Disabilities Act (ADA) and WCAG 2.1 Level AA guidelines. We are continuously working to improve accessibility. If you encounter an accessibility barrier, please contact us at compliance@elara.ai and we will make reasonable accommodations.

1N599 Labs maintains a comprehensive data privacy program. Key compliance commitments:

• CCPA / CPRA (California): Full compliance including no sale of personal information, consumer rights fulfillment, and annual data mapping
• GDPR / UK GDPR: Standard Contractual Clauses for EU/UK data transfers; Data Protection Officer designated
• COPPA: No collection of data from children under 13; parental consent required for users 13–17 for certain features
• GLBA: Safeguards Rule compliance for financial information (see Section 5)
• Texas Data Privacy and Security Act (TDPSA): Compliance with consumer rights under Texas law effective 2024

See our full Privacy Policy for detailed information on data practices.

The Platform may not be used to:

• Facilitate transactions involving OFAC-sanctioned individuals, entities, or jurisdictions
• Launder money or conceal the proceeds of illegal activity
• Facilitate fraud, wire fraud, mail fraud, or mortgage fraud
• Violate the USA PATRIOT Act or any counter-terrorism financing law
• Process transactions for properties subject to asset freezes or embargo

1N599 Labs reserves the right to freeze accounts, block transactions, and report suspicious activity to relevant authorities without prior notice.

By using the Platform, all users — including agents, brokers, Loan Officers, vendors, buyers, sellers, landlords, and tenants — agree to:

• Maintain any required professional licenses in current, valid standing
• Comply with all applicable federal, state, and local laws in their use of the Platform
• Make accurate representations in all listings, applications, and communications
• Not facilitate discrimination in housing, lending, or services
• Promptly report suspected violations to compliance@elara.ai

Failure to comply may result in suspension, termination, and/or referral to the applicable licensing authority or law enforcement.

1N599 Labs encourages good-faith reporting of potential compliance violations. Reports may be submitted anonymously to compliance@elara.ai.

1N599 Labs prohibits retaliation against any person who reports a compliance concern in good faith. Retaliation is itself a violation of this policy and may result in disciplinary action up to and including account termination.

1N599 Labs reviews this Compliance Policy at least annually and updates it as laws and regulations change. Material changes will be communicated via email and Platform notice at least 30 days before taking effect. Continued use of the Platform constitutes acceptance of the updated policy.