Privacy Policy — USHUD Cooperative

Effective Date: July 1, 2026

Overview

Heavy Hammer New Media Solutions, Inc. operates the USHUD Cooperative (“Cooperative,” “we,” “us,” or “our”) at www.ushudcooperative.com (the “Site”). The USHUD Cooperative is a membership platform providing real estate professionals — including agents, brokers, and teams — with access to consumer leads, advertising tools, IDX services, and related marketing resources distributed across the USHUD network of sites (USHUD.com, AllHud.com, HUDExchange.com, and USAHUD.com).

This Privacy Policy (“Policy”) describes how we collect, use, and protect the information you provide as a member or prospective member of the Cooperative. It does not govern our practices with respect to consumers who submit inquiries through the USHUD network — those individuals are covered by a separate consumer-facing privacy policy at USHUD.com.

By using the Site or enrolling as a member of the Cooperative, you agree to the collection and use of information as described in this Policy. Questions may be directed to [email protected] or:

1. What Information Do We Collect From You?

   We collect information in two categories: Personally Identifiable Information and Non-Personally Identifiable Information.

   Personally Identifiable Information includes information you provide when enrolling as a member, managing your account, or communicating with us. This may include:

   • Name, brokerage or company name, and professional license number
   • Mailing address, email address, telephone number, and mobile phone number
   • Payment information (credit card or ACH details) used to process membership fees
   • Professional profile content, including photo, bio, areas of service, and specializations
   • Login credentials for your member account

   Non-Personally Identifiable Information includes usage data that does not identify you individually, such as browser type, IP address, pages visited, and referring URLs. This information is compiled and analyzed to improve the performance and design of the Site and our member tools.

2. How Do We Collect and Use Your Information?

   We collect information when you enroll as a member, log in to manage your account, contact us for support, or interact with our platform. We use this information to:

   • Provision and manage your Cooperative membership
   • Distribute your professional profile to consumers on the USHUD network who match your selected service areas
   • Process membership fees and billing on a recurring basis
   • Send account notifications, billing alerts, renewal reminders, and service updates
   • Provide lead delivery notifications when new consumer inquiries matching your preferences are available
   • Communicate about upgrades, new features, and marketing opportunities available to members
   • Respond to support requests and account inquiries
   • Analyze platform usage to improve member tools and services

   Professional Profile Distribution: As a core function of your membership, your profile — including your name, photo, brokerage, contact information, and service areas — will be distributed to consumers on USHUD.com and the affiliated network sites based on your membership tier and selected coverage areas. You may update your profile at any time through your member account or by contacting [email protected].

   Newsletters & Marketing Emails: We may send members newsletters, product announcements, and promotional communications relevant to your membership. You may opt out of marketing emails at any time as described in Section 10. Transactional and account-related emails will continue regardless of marketing opt-out.

   SMS / Text Message Consent: By providing your mobile phone number during enrollment or account setup and expressly consenting to receive text messages, you agree that the USHUD Cooperative may send you SMS or MMS messages for purposes including new lead alerts, account notifications, billing reminders, membership renewal notices, and marketing communications about Cooperative services. Consent to receive text messages is not a condition of membership or any purchase. Message frequency varies based on your account activity. Standard message and data rates may apply. You may opt out at any time by replying STOP to any message. For help, reply HELP or contact us at [email protected] or 800-880-8584.

   Cookies: We use cookies and similar tracking technologies to maintain your session, remember your preferences, and analyze Site usage. See Section 8 for details.

3. Who Is Collecting Your Information?

   Except as expressly described in this Policy, the USHUD Cooperative is the sole entity collecting your information on this Site. We encourage you to review the privacy policies of any third-party platforms linked from or integrated with the Site.

   Third-Party Service Partners: We may engage third-party vendors to assist with payment processing, email delivery, CRM services, analytics, and advertising. These vendors receive only the information necessary to perform their designated function and may not use your information for any other purpose.

   Analytics and Tracking: We may use third-party analytics providers to track traffic and usage patterns on the Site. These providers collect Non-Personally Identifiable Information and, in some cases, email addresses.

4. With Whom Do We Share Your Information?

   We do not sell, trade, or rent your Personally Identifiable Information to third parties. We share your information only as described below.

   Service Providers: We share information with third-party vendors who support our operations, including payment processors, email platforms, CRM tools, and hosting providers. These parties are contractually prohibited from using your information for any purpose other than providing services to us.

   Consumer-Facing Profile Distribution: As part of your membership, your professional profile is shared with consumers on USHUD.com and affiliated network sites. This includes your name, photo, contact information, brokerage, and service areas. It does not include payment information or login credentials.

   SMS / Text Messaging Originator Data — No Third-Party Sharing:

   No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties, excluding aggregators and providers of the Text Message services.

   Text messaging originator opt-in data and consent will not be shared with any third parties, except for aggregators and providers of the Text Message services.

   Legal Compliance: We may disclose your information if required by law, court order, or government request, or if we believe in good faith that disclosure is necessary to protect the rights, property, or safety of the Cooperative, its members, or the public.

   Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of our assets, your information may be transferred to the successor entity and will remain subject to this Policy.

   Your California Privacy Rights: California residents may request information about any personally identifiable information we share with third parties for direct marketing purposes. To make such a request, contact us at [email protected] or write to: Mail Preference Service, 65 Old Solomons Island Rd, Suite 202, Annapolis, MD 21401. We will respond within thirty (30) days.

5. How May You Update, Correct, or Delete Your Information?

   You may review and update your member profile at any time by logging into your account or contacting us at [email protected]. To request deletion or correction of your account information, contact us in writing at [email protected]. Please note that we may retain certain information as required by law or to fulfill legitimate business purposes such as billing history and dispute resolution.

6. What Are Your Choices Regarding Communications?

   Marketing Emails: You may opt out of marketing and promotional emails at any time by:

   1. Clicking the unsubscribe link in any marketing email;
   2. Calling us at 800-880-8584; or
   3. Emailing [email protected] with your request.

   Account-related and transactional emails (such as billing confirmations, renewal notices, and lead delivery alerts) will continue regardless of marketing opt-out, as they are necessary to administer your membership.

   SMS / Text Messages: You may opt out of text messages at any time by replying STOP to any text message we send. Upon receiving STOP, we will send a single final confirmation SMS and will not send further messages unless you re-opt in. To re-opt in, contact us at [email protected] or sign up again through your account settings. For help, reply HELP.

7. How Do We Protect Your Information?

   We employ industry-standard security measures to protect your information, including password protection, advanced encryption, and firewall technology. Payment transactions are processed through established third-party payment processors using encrypted, secured connections. All customer data is protected against unauthorized access by physical and technical security controls.

   We encourage our vendors and partners to maintain similarly stringent security practices. However, no data transmission over the Internet can be guaranteed to be 100% secure. You transmit information to us at your own risk and are responsible for maintaining the confidentiality of your account credentials.

8. Cookies and Tracking Technologies

   We use cookies and similar technologies (including clear GIFs and pixel tags) to operate the Site, maintain your session, remember your preferences, and analyze usage patterns. Cookies are small text files stored on your device by your browser. You may configure your browser to refuse cookies or alert you when cookies are being sent; however, some features of the Site may not function properly without cookies.

   We may work with third-party analytics and advertising partners (such as Google) that use cookies or pixel tags to measure the effectiveness of our campaigns and improve Site performance. These partners may use information about your visits to this and other websites to provide targeted advertising. Their use of such information is governed by their own privacy policies.

9. SMS / Text Messaging — A2P 10DLC Compliance

   The USHUD Cooperative complies with Application-to-Person (A2P) 10DLC messaging registration requirements imposed by U.S. mobile carriers and The Campaign Registry (TCR). The following terms govern all SMS and MMS communications sent by the USHUD Cooperative to its members and prospective members:

   Program Name: USHUD Cooperative Member SMS Program

   Recipients: Real estate agents, brokers, and teams enrolled in or inquiring about USHUD Cooperative membership.

   Message Types: Messages may include new lead and consumer inquiry alerts, membership account notifications, billing and renewal reminders, platform feature announcements, and marketing communications about Cooperative services and upgrades.

   Consent: By providing your mobile phone number during enrollment or account setup and affirmatively opting in, you consent to receive text messages from the USHUD Cooperative. Consent is not a condition of membership or any purchase.

   Opt-Out: Text STOP at any time to unsubscribe. You will receive a final confirmation SMS, after which no further messages will be sent unless you re-opt in.

   Re-Opt-In: To resume receiving messages, contact us at [email protected] or sign up again through your account settings.

   Help: Text HELP for assistance, or contact us at [email protected] or 800-880-8584.

   Carrier Disclaimer: Carriers are not liable for delayed or undelivered messages.

   Rates: Message and data rates may apply. Message frequency varies based on your account activity and notification preferences. Contact your wireless provider for questions about your text or data plan.

   No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties, excluding aggregators and providers of the Text Message services.

10. Children and Privacy

    The USHUD Cooperative is a professional membership platform intended solely for licensed or practicing real estate professionals aged 18 and older. We do not knowingly collect Personally Identifiable Information from anyone under the age of 18. If we learn that we have inadvertently collected information from a minor, we will delete such information and terminate the associated account promptly.

11. Right to Opt-Out

    The following opt-out rights apply to all members and users of the USHUD Cooperative, regardless of location.

    1. California Members. California’s “Shine the Light” law (Civil Code § 1798.83) and the CCPA provide California residents with additional privacy rights, including the right to know what personal information is shared and with whom. To exercise your California rights, contact us at [email protected] or write to: Mail Preference Service, 65 Old Solomons Island Rd, Suite 202, Annapolis, MD 21401. We will respond within thirty (30) days.
    2. SMS / Mobile Opt-Out. Reply STOP to any text message at any time to unsubscribe. No SMS opt-in data or mobile consent will be shared with any third party for marketing purposes.
    3. Email Marketing Opt-Out. Follow the unsubscribe instructions in any marketing email, or contact us at [email protected]. Transactional and account emails will continue as necessary to administer your membership.
    4. Exceptions. If you have opted out and subsequently request a service or promotion that requires us to contact you or share your information, your prior opt-out will not apply to that specific service. Service-related communications may continue regardless of opt-out status as permitted by applicable law.
    5. Device Notifications. If you use our mobile applications or browser notifications, you may manage alert preferences through your device or browser settings.

12. Third-Party Sites and Integrations

    The USHUD Cooperative Site may contain links to third-party websites, platforms, or tools (including IDX providers, CRM integrations, and advertising platforms). We are not responsible for the privacy practices or content of those third parties. We encourage you to review the privacy policies of any third-party services you access through or alongside your Cooperative membership.

13. Contact Us

    If you have any questions about this Policy or your information, please contact us:

    USHUD Cooperative / Heavy Hammer New Media Solutions, Inc.
    65 Old Solomons Island Rd., Suite 202
    Annapolis, MD 21401
    Email: [email protected]
    Phone: 800-880-8584
    

14. Policy Changes

    This Policy was last updated on July 1, 2026. We will post any changes to this page and update the effective date above. Material changes will be communicated to active members via email. Continued use of the Site or your membership after any changes constitutes acceptance of the updated Policy.