Nondiscrimination Policy

1. Who This Policy Applies To

This Policy applies to:

• CurbPage, Inc. and its employees, contractors, and representatives, in connection with their operation of the Platform and treatment of users;

• All agents, transaction coordinators, and brokerage administrators who use the Platform, in connection with their use of the Platform and their interactions with clients managed through the Platform;

• Brokerage entities whose agents or staff access the Platform under a brokerage account; and

• Any other individual or organization that accesses or uses the Platform in any capacity.

By creating an account or using the Platform, you agree to comply with this Policy. Compliance with this Policy is a condition of your continued access to the Platform.

2. CurbPage's Commitment to Its Users

2.1 Equal Access to the Platform

CurbPage is committed to providing equal access to the Platform to all eligible users without discrimination. CurbPage will not deny access to, suspend, terminate, or impose different terms on any user's subscription based on that user's race, color, religion, national origin, sex, gender identity, sexual orientation, disability, age, familial status, marital status, pregnancy, veteran status, or any other characteristic protected by applicable federal, state, or local law.

2.2 Nondiscriminatory Pricing and Features

CurbPage will not offer different subscription pricing, feature access, customer support, or other terms to users based on any protected characteristic. All users at the same subscription tier receive the same features and service levels. Any pricing differences are based solely on subscription plan, billing cycle, or promotions that are offered uniformly and without discriminatory intent.

2.3 Respectful Treatment

CurbPage's team—including support staff, sales representatives, territory managers, and any other individuals who interact with users on CurbPage's behalf—is expected to treat all users with equal respect and professionalism. CurbPage will not tolerate discriminatory, harassing, or demeaning conduct by its own team members toward any user.

2.4 Product Design

CurbPage is committed to ensuring that the Platform's design, features, and algorithms do not perpetuate or encode discriminatory outcomes. To the extent CurbPage uses data to improve the Platform or personalize user experience, it will do so in a manner that does not systematically disadvantage users or their clients on the basis of protected characteristics.

3. Agent Obligations: Nondiscrimination Toward Clients

3.1 The Core Obligation

Agents and other users of the Platform must not use the Platform—including its communications tools, transaction management features, client portal, task management system, or any other feature—as a means to discriminate against any client or prospective client on the basis of any protected characteristic.

This obligation applies throughout the entire client relationship managed through the Platform, including but not limited to:

• Deciding whether to take on or communicate with a prospective client;

• The quality, speed, or completeness of service delivered through the Platform;

• The information shared with a client through the Platform's client-facing portal;

• How a transaction is organized, prioritized, or managed within the Platform;

• Communications sent through the Platform's messaging features; and

• How agent profiles, property data, or transaction timelines are presented to clients.

3.2 Equal Service Delivery

Every client added to the Platform is entitled to receive the same quality of service through the Platform as any other client of the same agent. Agents must not use the Platform's features to provide systematically inferior service to some clients compared to others based on protected characteristics. This includes, but is not limited to, creating less complete transaction pages, sharing less information through the client portal, or communicating less frequently or thoroughly with certain clients.

3.3 Client Data Integrity

Agents must not record, store, or otherwise use the Platform to maintain notes, tags, or client classifications that reflect discriminatory intent or that could facilitate discriminatory treatment. Any data entered into the Platform regarding a client must reflect legitimate, lawful, transaction-relevant information only.

4. Fair Housing Law and This Platform

4.1 The Legal Framework

Real estate agents are subject to a robust body of federal and state law prohibiting discrimination in housing-related activities. The most significant of these laws include:

• The Fair Housing Act (42 U.S.C. §§ 3601–3619): Federal law prohibiting discrimination in the sale, rental, and financing of housing based on race, color, national origin, religion, sex, familial status, and disability.

• The Civil Rights Act of 1866 (42 U.S.C. § 1982): Prohibits racial discrimination in all property transactions.

• The Americans with Disabilities Act (ADA): Requires reasonable accommodations for individuals with disabilities in certain real estate contexts.

• State and Local Fair Housing Laws: Many states and municipalities extend fair housing protections beyond the federal baseline to include additional protected classes such as sexual orientation, gender identity, source of income, marital status, age, and others. Agents must be aware of and comply with all applicable laws in their jurisdiction.

• NAR Code of Ethics, Article 10: REALTORS® are prohibited from discriminating against any person on the basis of race, color, religion, sex, disability, familial status, national origin, sexual orientation, or gender identity in providing real estate brokerage services.

4.2 CurbPage Is a Tool; You Are the Professional

CurbPage is a technology platform, not a licensed real estate broker or transaction coordinator. CurbPage does not provide legal advice regarding fair housing compliance. The obligations described in this Section and throughout this Policy reflect your pre-existing legal and professional obligations as a licensed real estate agent—CurbPage is simply making clear that the Platform may not be used in a manner that violates those obligations.

You are solely responsible for understanding and complying with all fair housing laws and professional ethics rules applicable to your real estate practice. CurbPage strongly encourages all agents to complete fair housing training and to consult legal counsel if they have questions about their obligations.

4.3 No Steering

Agents must not use the Platform in any manner that constitutes illegal steering—that is, directing clients toward or away from particular neighborhoods, properties, or markets based on the race, national origin, religion, or other protected characteristics of the client or of the residents of those areas. This prohibition applies to the information shared through the Platform's client portal, the framing of property recommendations, and all communications sent through the Platform.

4.4 No Redlining Through Data

Agents must not use the Platform's transaction management, geographic, or market data features to implement or facilitate any form of redlining or other geographic discrimination based on the demographic characteristics of an area. All clients must have equal access to the agent's services across all geographies in which the agent operates.

5. Protected Characteristics

This Policy prohibits discrimination on the basis of any of the following characteristics, as well as any characteristic protected by applicable federal, state, or local law:

• Race and Color: Including racial background, skin color, and characteristics historically associated with race.

• National Origin and Ethnicity: Including country of birth, ancestry, ethnic background, and immigration status.

• Religion: Including religious beliefs, practices, and affiliation, or lack of religious affiliation.

• Sex: Including biological sex, pregnancy, childbirth, and related medical conditions.

• Gender Identity: Including an individual's self-identified gender, regardless of the sex assigned at birth.

• Sexual Orientation: Including actual or perceived homosexuality, heterosexuality, bisexuality, and related characteristics.

• Disability: Including physical, mental, or developmental disabilities, whether actual, perceived, or historical, and including the use of assistance animals.

• Familial Status: Including having children under the age of 18, pregnancy, and seeking custody of children.

• Marital Status: Including being married, single, divorced, widowed, or in a domestic partnership.

• Age: Including both protection of older individuals under applicable law and protection against age-based discrimination more broadly.

• Veteran or Military Status: Including active duty service members, veterans, and members of the National Guard or Reserves.

• Source of Income: In jurisdictions where protected by law, including the use of housing vouchers, Section 8, or other government assistance.

• Caste: Including discrimination based on hereditary social stratification systems.

This list is illustrative and not exhaustive. CurbPage may expand protected characteristics under this Policy from time to time as laws evolve or as consistent with our values.

6. Prohibited Conduct

6.1 Prohibited Conduct by Agents Toward Clients

Agents and other users are prohibited from using the Platform to:

• Refuse to create a transaction or client record for a prospective client on the basis of a protected characteristic;

• Provide materially inferior service through the Platform to clients based on their protected characteristics, including by creating less complete transaction records, sharing less information through the client portal, or communicating less frequently or responsively;

• Record or store in the Platform any information about a client that reflects discriminatory intent, including coded language, demographic tags, or notations designed to identify clients by protected characteristics for the purpose of differential treatment;

• Use the Platform's communications tools to send messages that are discriminatory, harassing, derogatory, or demeaning toward any client based on a protected characteristic;

• Selectively share or withhold transaction information through the Platform based on a client's protected characteristics;

• Organize or prioritize transactions in a manner that systematically disadvantages clients based on protected characteristics; or

• Use any data or feature of the Platform to implement or facilitate illegal steering, redlining, or other discriminatory real estate practices.

6.2 Prohibited Conduct by CurbPage Toward Users

CurbPage and its team members are prohibited from:

• Denying access to the Platform to any eligible user based on a protected characteristic;

• Offering different subscription pricing, features, or customer support quality to users based on a protected characteristic;

• Discriminating against any user in the onboarding, sales, or support process based on a protected characteristic;

• Using language in the Platform, marketing materials, or communications that demeans, stereotypes, or excludes any group based on a protected characteristic; or

• Building Platform features that encode, perpetuate, or facilitate discrimination against protected groups.

6.3 Prohibited Language and Content

No user of the Platform may use the Platform's communication or content features to post, transmit, or share:

• Slurs, epithets, or derogatory terms targeting any person or group based on a protected characteristic;

• Language that denies, demeans, or stereotypes individuals based on a protected characteristic;

• Content that calls for differential treatment of, segregation of, or violence toward any group based on a protected characteristic;

• Discriminatory symbols, imagery, or iconography of any kind; or

• Microaggressions or coded language intended to convey bias or contempt toward any person or group.

7. Language, Content, and Communications

7.1 Professional and Inclusive Language

All communications sent through the Platform—including messages to clients, notes within transaction records, and any other content created or transmitted through the Platform—must be professional, accurate, and free of discriminatory content. CurbPage's brand voice commits to language that is empathetic and inclusive, and we expect the same of all users when using our tools to communicate.

7.2 Pronouns and Identity

CurbPage expects all users to respect the self-identified gender and pronoun preferences of clients and other users. If a client has expressed a pronoun preference or other identity preference, that preference must be respected in all Platform communications. Users must not misgender, deadname, or otherwise disrespect the gender identity of any client or user.

7.3 Client-Facing Content

Agents are responsible for ensuring that all content visible to clients through the Platform's client portal—including transaction titles, task descriptions, vendor information, documents, and messages—is professional, accurate, and free of any discriminatory content. Clients should receive a consistent, high-quality experience through the Platform regardless of their protected characteristics.

7.4 Accessibility of Communications

Agents must not refuse to communicate with clients through accessible means available to them. Where a client communicates a need for an accessible format—such as written communication, larger text, or other accommodation—agents should make reasonable efforts to accommodate that need in their use of the Platform.

8. Accessibility

8.1 Platform Accessibility

CurbPage is committed to making the Platform accessible to users with disabilities. CurbPage works toward compliance with the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA standards for its web application. If you encounter an accessibility barrier on the Platform, please contact us at hello@curbpage.com and we will make reasonable efforts to address the issue.

8.2 Clients with Disabilities

Agents must not use the Platform in a manner that discriminates against clients with disabilities. Specifically, agents must not:

• Provide inferior service through the Platform to clients based on their disability status;

• Refuse to communicate with a client through accessible means that are available and reasonable;

• Record disability-related information about a client in the Platform for any discriminatory purpose; or

• Use the Platform to facilitate any refusal of reasonable accommodation requests to which a client may be legally entitled.

8.3 Assistance Animals

In connection with real estate transactions managed through the Platform, agents must not use the Platform to facilitate any unlawful denial of reasonable accommodations for clients with disabilities, including accommodations related to assistance animals. Applicable fair housing law generally requires that housing providers make reasonable accommodations for individuals with disabilities who use assistance animals, and agents must comply with these obligations independently of their use of the Platform.

9. Permissible Distinctions

9.1 Legitimate Business Distinctions

This Policy does not prohibit all distinctions between clients—only those based on protected characteristics. Agents may lawfully make distinctions based on factors that are genuinely unrelated to protected characteristics, including:

• A client's expressed preferences, needs, or instructions;

• The geographic scope or specialization of the agent's practice, applied uniformly;

• A client's budget, financing status, or timeline, where these factors are transaction-relevant and not used as proxies for protected characteristics;

• Capacity constraints that apply equally to all prospective clients without regard to protected characteristics; or

• Any other distinction that has a legitimate, non-discriminatory justification.

9.2 Legal Requirements

Nothing in this Policy requires agents to violate applicable law. Where a specific provision of federal, state, or local law requires or permits a specific practice that would otherwise appear to conflict with this Policy, agents should consult legal counsel regarding their obligations. CurbPage does not provide legal advice on this matter.

9.3 Senior Housing and Age-Restricted Communities

Real estate agents working with housing developments that qualify for the senior housing exemption under the Fair Housing Act (55+ communities and 62+ communities) may use the Platform to manage transactions for those properties in compliance with applicable federal exemptions and state law. Agents are responsible for ensuring that any age restrictions applied are consistent with applicable law and are not used as a pretext for other forms of discrimination.

10. Reporting a Violation

10.1 How to Report

If you believe you have experienced or witnessed a violation of this Policy—whether by another user of the Platform or by CurbPage itself—please contact us at:

Email: hello@curbpage.com

Subject line: "Nondiscrimination Policy Report"

Your report should include: (a) a description of the conduct you believe violated this Policy; (b) the date(s) on which the conduct occurred; (c) any relevant Platform records, screenshots, or communications that document the alleged violation; and (d) your contact information for follow-up.

10.2 Confidentiality

CurbPage will handle all discrimination reports with sensitivity and discretion. To the extent possible, CurbPage will maintain the confidentiality of the reporting party's identity during any investigation. However, complete confidentiality cannot be guaranteed where disclosure is necessary to investigate the report or is required by law.

10.3 No Retaliation

CurbPage strictly prohibits retaliation against any user who, in good faith, reports a potential violation of this Policy, participates in an investigation, or opposes conduct that they reasonably believe violates this Policy or applicable law. Retaliation is itself a violation of this Policy and the Terms of Service and may result in immediate account termination.

10.4 External Reporting

Nothing in this Policy limits your right to file a complaint with a government agency, including the U.S. Department of Housing and Urban Development (HUD) at hud.gov/program_offices/fair_housing_equal_opp, your state's civil rights agency, or any other applicable regulatory body. CurbPage encourages users to report potential Fair Housing Act violations to the appropriate authorities in addition to reporting them to CurbPage.

11. Enforcement

11.1 Investigation

CurbPage takes all reports of discrimination seriously. Upon receiving a report, CurbPage will review the available information and conduct a good-faith investigation appropriate to the nature of the reported violation. CurbPage may contact relevant parties to gather additional information during the investigation.

11.2 Consequences

If CurbPage determines that a user has violated this Policy, CurbPage may take one or more of the following actions depending on the severity and nature of the violation:

• Issuing a written warning to the violating user;

• Requiring the user to complete fair housing or nondiscrimination training;

• Requiring the removal of any discriminatory content from the Platform;

• Temporarily suspending the user's access to the Platform;

• Permanently terminating the user's account and subscription without refund; or

• Reporting the conduct to the applicable real estate licensing authority, MLS, brokerage, or law enforcement, where warranted.

CurbPage reserves the right to determine the appropriate response to any violation in its sole discretion, and to take action against violations that occur off the Platform where those violations relate to the user's use of the Platform or their treatment of clients managed through the Platform.

11.3 Violations by CurbPage

If a user believes that CurbPage itself has violated this Policy in its treatment of users, the user may file a report as described in Section 10.1. Reports alleging CurbPage's own violations will be reviewed by CurbPage's leadership. Users who believe CurbPage has engaged in unlawful discrimination may also file a complaint with applicable federal or state agencies.

11.4 No Guarantee of Specific Outcome

CurbPage does not guarantee any particular outcome from its enforcement process. CurbPage's investigation and enforcement actions are entirely internal and do not substitute for, and do not preclude, any external legal remedies available to affected parties.

12. Relationship to Applicable Law

12.1 Compliance with Law

This Policy is intended to operate alongside and in support of applicable federal, state, and local nondiscrimination laws. Where applicable law provides greater protections than this Policy, applicable law governs. Where this Policy provides greater protections than the law requires, this Policy governs to the extent permitted by law.

12.2 Policy Does Not Create Legal Liability for CurbPage

This Policy reflects CurbPage's internal standards and user obligations. It is not intended to create legal liability for CurbPage in connection with the discriminatory acts of users. Agents and other users are solely responsible for their own compliance with applicable nondiscrimination laws. CurbPage's enforcement of this Policy does not make CurbPage a party to any transaction or responsible for any agent's professional conduct.

12.3 Users Remain Independently Obligated

Compliance with this Policy does not substitute for compliance with applicable law. Users remain independently obligated to comply with the Fair Housing Act, applicable state fair housing laws, the NAR Code of Ethics, and all other applicable legal and professional standards, regardless of this Policy's requirements.

13. Modifications to This Policy

CurbPage may update this Policy from time to time to reflect changes in applicable law, evolving best practices, or CurbPage's own standards. Material changes will be communicated to users via email and/or in-Platform notification at least 14 days before the updated Policy takes effect. Continued use of the Platform following the effective date of any update constitutes acceptance of the revised Policy.

CurbPage will maintain a version history for this Policy so that users can review the changes made over time. Prior versions will be available upon request.

14. Contact

For questions about this Policy, to report a potential violation, or to request a reasonable accommodation in connection with your use of the Platform, please contact us:

CurbPage, Inc.

Email:    hello@curbpage.com

Website:  curbpage.com

A note from our team:  We built CurbPage because we believe every client deserves to feel valued and understood. That belief only means something if it extends to every client—without exception. If you ever have a concern about how this platform is being used, we want to hear from you.