Privacy Policy – SEB Housing Waitlist Platform

Effective Date: June 17, 2026 · Last Updated: November 2, 2026

This Privacy Policy describes how SEB Housing ("SEB Housing," "we," "us," or "our") collects, uses, and protects personal information in connection with our Sebastion platform, which includes: our online waitlist application, which you access through a secure link that is unique to a particular property's waitlist (the "Waitlist Application"); the Sebastion Applicant Portal, located at applicant.sebhousing.com (the "Applicant Portal"), where applicants can view the status of their waitlist applications; and the SEB Housing Waitlist Management Platform, located at waitlist.sebhousing.com (the "Management Platform"), which property staff use to manage waitlists. In this Privacy Policy, the Waitlist Application and the Applicant Portal are referred to together as the "Applicant Services." Sections 1 through 8 describe how we handle applicant information. Section 9 describes the information we collect about property staff who use the Management Platform.

Use of the Applicant Portal is also governed by the Sebastion Applicant Portal Terms of Service, and use of the Management Platform is governed by the SEB Housing Waitlist Management Platform Terms of Service. This Privacy Policy provides the complete description of how we handle personal information and controls if the Applicant Portal Terms of Service differ on a privacy matter. For participating properties, any signed service agreement or data processing agreement with SEB Housing governs our obligations to that property.

Please read this Privacy Policy carefully. By submitting your information through the Waitlist Application, using the Applicant Portal, or using the Management Platform, you agree to the practices described below.

1. Who We Are

SEB Housing is an income-restricted housing compliance consultant. Our corporate website is sebhousing.com. The Waitlist Application, the Applicant Portal, and the Management Platform are official SEB Housing services, part of our Sebastion platform, used to manage applicant waitlists and certifications on behalf of residential property owners and operators ("participating properties"). We manage applicant information on behalf of the participating property where you applied, under our agreement with that property. The property is ultimately responsible for decisions about your application and tenancy, including matching you to a unit at lease signing.

2. Information We Collect

When you submit a waitlist application, we may collect the following information:

• Full name
• Email address
• Phone number
• Current physical address
• Date of birth
• Household size and dependent information
• Income information and assets (where applicable, to assess eligibility for income-restricted units)
• Program preferences you indicate on your application (for example, local preference or special program eligibility)
• Accessibility needs or unit feature requirements you request, such as a mobility-accessible unit

We do not collect Social Security numbers, payment card information, financial account details, or income or eligibility documentation through the Applicant Services or the Management Platform. Any such documentation is handled outside the platform. If this changes, we will update this Privacy Policy before collecting it.

When you use the Applicant Portal, we also collect:

• Records of the secure access links (magic links) sent to your email address, including when they are requested and used
• Login activity, such as when you logged in and the type of device you used
• Your notification preferences and any waitlist opt-out selections

If you apply or use the Applicant Portal on behalf of another applicant, we may also collect your name and contact information as their authorized representative.

3. Why We Collect This Information

We collect your information for the following purposes:

• Waitlist management – To place you on and manage your position in a property waitlist.
• Applicant Portal access – To verify your access through secure links sent to your email address and to show you your waitlist applications, application status, and approximate waitlist position.
• Eligibility determination – To assess whether you meet the eligibility requirements for specific housing programs (e.g., age-restricted, income-restricted, or HUD-regulated units).
• Communication – To contact you through the SEB newsletter or about your application and account, including User Account invitations, eligibility screening invitations and results, pre-rental and rental application invitations and notices, when a unit becomes available, and when your application status changes. You may be contacted by SEB Housing or property staff. Property staff will contact you directly at certain points in the process, such as after eligibility screening, the rental application, and at lease-up.
• Regulatory compliance – To comply with applicable federal, state, and local housing and fair housing regulations, including requirements set by the U.S. Department of Housing and Urban Development (HUD).
• Platform administration and support – To administer the platform on behalf of participating properties, provide support, keep the platform secure, and prevent misuse.

We do not sell, rent, or share your personal information with third parties for marketing or advertising purposes. Your application information is shared with the property owner or operator on whose behalf SEB Housing is administering the waitlist, and otherwise only in the limited circumstances described in Section 6 (Information Sharing).

4. Sensitive Information, Fair Housing, and Accommodations

Certain fields — including date of birth, household income, household composition, and any accessibility needs you request — are collected because they are necessary to determine eligibility, preference, and unit fit under the terms of SEB Housing's participation in regulated income-restricted housing programs. These programs may require compliance with HUD guidelines and/or other applicable federal, state, and local regulations.

We understand that sharing this information requires trust. We are committed to collecting only what is necessary and protecting what you share with us.

SEB Housing is committed to fair housing. We do not use race, color, national origin, religion, sex, familial status, disability, or any other characteristic protected by fair housing law to determine your waitlist position or your access to the Applicant Services, except where the law, program rules or regulations permit or require it — for example, to match applicants with accessible units, to administer age-restricted housing programs, or to apply occupancy and bedroom-size standards. Information about disability or accessibility needs is used only for these purposes and to provide reasonable accommodations. If you believe you have experienced discrimination, you may file a complaint with the U.S. Department of Housing and Urban Development (HUD) online at hud.gov/fairhousing or by phone at 617-994-8300, or by calling the Massachusetts Commission Against Discrimination at 617-727-3990.

How accommodation requests are handled depends on the type of request:

• Accommodations to use the Applicant Services – If you need an accommodation to access or use the Applicant Services, such as alternative formats or help viewing your waitlist information, SEB Housing handles your request. Contact us at waitlist@sebhousing.com.
• Housing accommodations – If you request a housing-related accommodation, such as a mobility-accessible unit, SEB Housing records your request and, using unit information provided by the property, places you on the appropriate waitlist. The property is responsible for making sure you are matched to an appropriate unit at lease signing.

5. How We Store and Protect Your Information

• All data submitted through or displayed in the Applicant Services and the Management Platform is transmitted using industry-standard SSL/TLS encryption.
• Data is stored in secure, access-controlled systems. Access to applicant data is limited to authorized SEB Housing staff and staff at participating properties on a need-to-know basis, as described in Section 6.
• Waitlist Application access links are unique to you, tied to your email address, and expire after a set period of time. Please do not share your access links, and keep your email account secure.
• Applicant Portal log in invitations are tied to your email address. If you believe your email account has been compromised and you wish to update it, contact us at waitlist@sebhousing.com.
• We retain waitlist data for as long as your application remains active, as necessary to fulfill the purposes described in this Privacy Policy, or as required by applicable law, including housing program record-keeping requirements. If you are removed from all waitlists, your Applicant Portal access is deactivated, but we may continue to retain your records where required by law.
• If a property stops using our platform, SEB Housing stops managing that property's waitlists. We freeze the waitlist data as of that date and turn it over to the property, which then manages your information under its own policies.
• If you opt out of a waitlist, we keep a record of your opt-out so that it is honored and you are not re-added to that waitlist without re-applying.
• We do not store payment card numbers or other financial account credentials.
• No online system is completely secure, and we cannot guarantee the security of information transmitted over the internet.
• If a security breach affects your personal information, SEB Housing and/or the property you applied to will notify you as required by applicable law.

6. Information Sharing

We do not sell your personal information. We may share your information in limited circumstances:

• Service providers – We work with technology vendors (such as our hosting provider) and other third-party services integrated with our platform, which process data on our behalf under confidentiality agreements.
• Legal requirements – We may disclose information if required by law, court order, program compliance or governmental authority.
• Housing partners – Waitlist data is shared with the property owner or operator on whose behalf SEB Housing is administering the waitlist, solely for the purpose of processing your application. Staff at each participating property can see your application data, waitlist position, and application status for their property only, and may use your contact information to communicate with you about your application. They cannot see your information for other properties through the platform.
• SEB Housing staff – Authorized SEB Housing staff can view your application data, Applicant Portal login activity, and notification and opt-out selections solely to administer the platform, provide support, and ensure compliance with fair housing requirements.
• Business transfers – If SEB Housing is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. It will remain subject to this Privacy Policy and to our agreements with participating properties.

7. Your Rights and Choices

Depending on where you live, you may have certain rights regarding your personal information, including:

• The right to access the information we hold about you
• The right to correct inaccurate information. Application information cannot be changed through the Applicant Portal; to correct it, or to update your email address or household information, contact the property you applied to or SEB Housing using the information below.
• The right to request deletion of your information (subject to legal retention requirements)
• The right to withdraw your waitlist application at any time, including by opting out of a waitlist in the Applicant Portal. Opting out is generally permanent; to rejoin, you would need to re-apply if the waitlist is open.
• The right to manage your notification preferences in the Applicant Portal (some notices required by the waitlist process cannot be turned off)
• The right to ask that your Applicant Portal access be closed (this does not withdraw your waitlist application)

Depending on your state of residence, you may have additional rights under applicable state privacy laws. SEB Housing does not sell personal information. To exercise any of these rights, contact us at the information below.

Because SEB Housing manages applicant information on behalf of participating properties, we may need to coordinate with the property you applied to in order to respond to some requests.

If you need a reasonable accommodation to use the Applicant Services or to exercise these rights — including alternative formats or assistance accessing your waitlist information — please contact us at waitlist@sebhousing.com.

8. Age Requirements and Authorized Representatives

The Applicant Services are intended for adults. You must be 18 years of age or older, or an emancipated minor, to use the Applicant Portal or to submit a waitlist application on your own behalf. We do not knowingly collect personal information directly from minors.

Information about minor household members, such as dependents, is collected only as part of an adult applicant's application. If you believe a child has submitted information through the Applicant Services, please contact us immediately.

If you submit an application or use the Applicant Portal on behalf of another applicant — for example, as a legal guardian or authorized representative — you represent that you have authority to do so. We handle the applicant's information as described in this Privacy Policy.

9. Information About Property Staff Users

This section applies to property owners, property managers, leasing agents, compliance staff, and other authorized users who access the Management Platform on behalf of a participating property.

The only personal information we collect about property staff users is the email address used to invite you to and sign into your account. Your password is stored in protected form and is used only to authenticate you.

We use your email address only to provide access to the Management Platform, send account invitations and service notices, and communicate with you about the platform. We do not sell it or use it for marketing by third parties. To update or remove your account, contact your property's administrator or SEB Housing at waitlist@sebhousing.com or through the contacts listed on your Notify List in the Management Platform.

Applicant information you access through the Management Platform belongs to your property and must be handled as described in the SEB Housing Waitlist Management Platform Terms of Service and your property's agreement with SEB Housing.

10. Contact Us

If you have questions about this Privacy Policy, wish to exercise your data rights, or need to report a privacy concern, please contact us:

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last Updated" date at the top of this page and, where required by law or where a change materially affects your rights, notify you by email. We encourage you to review this Privacy Policy periodically.

The Waitlist Application, the Applicant Portal, and the Management Platform are official services of SEB Housing. If you did not intend to apply for SEB Housing waitlists, please do not submit your information and navigate away from this page.