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Data Sourcing Policy

Why this document exists

Rent pricing software has come under significant legal and regulatory scrutiny. Federal and state enforcement actions, along with new laws in several states and cities, have focused on a specific practice: software that collects nonpublic, competitively sensitive information from competing landlords and uses it to generate pricing recommendations returned to those same competitors.

Inktrue was built after that scrutiny began, and it was built deliberately to sit outside that practice.

This document explains, in specific terms, what data goes into an Inktrue rent estimate and what data never does. It is published separately from our Terms of Use and Privacy Policy because those documents govern your relationship with us, and this one governs how our product works. We think you should be able to read it without a lawyer, and we think your lawyer should be able to read it too.

The principle

Information supplied by one landlord is never used to generate an estimate delivered to a different landlord.

That is the whole policy. Everything below is an elaboration of it.

We do not operate a data pool. We do not run a contributor exchange. There is no arrangement in which providing us with your operational data earns you better estimates informed by someone else's operational data. That model is the one regulators have acted against, and we do not use it.

Inktrue does not perform a coordinating function

The state and municipal laws governing rent pricing software are built around a defined term: coordinating function. The definition originated in proposed federal legislation and has since been adopted, with variations, in state statutes and city ordinances across the country.

In the most widely adopted formulation, software performs a coordinating function only if it does all of the following, where the inputs come from two or more property owners or managers that are not under common ownership:

  • Collects historical or contemporaneous prices, supply levels, or lease termination and renewal dates from those owners or managers
  • Processes that information computationally
  • Produces price, occupancy, or lease term recommendations from it

Inktrue does not perform a coordinating function, and we commit that we will not build one.

We do not satisfy the first element. We do not collect price information, supply or occupancy information, or lease termination or renewal dates from multiple property owners or managers for use in pricing one another's units. Where a property owner tells us what their own unit currently rents for, that information informs only that owner's own report and is excluded from the data used to produce estimates for anyone else. This is described in The partition rule below.

Because the definition requires all three elements together, our position is that the analysis does not reach the second or third. We nonetheless maintain constraints on both, described in Limits on what our product does, because we think a pricing tool should be defensible on its outputs as well as its inputs.

Some ordinances use narrower or differently worded formulations, most commonly targeting software that combines nonpublic competitor data to set or recommend rents and occupancy levels. We do not combine nonpublic competitor data, and we do not recommend occupancy levels.

This commitment is architectural. It is enforced in our data pipeline rather than maintained as an internal guideline, and we treat it as a permanent constraint on the product rather than a current-version limitation.

What we use

Publicly published information. The core of our estimate is built from information that is already published to the general public, including prospective tenants:

  • Advertised asking rents from public rental listings
  • Published market indices covering rent levels, home values, and rent forecasts
  • Federal survey and census data on housing, vacancy, income, and household composition
  • Public property records, including assessor data, deed records, and permit filings
  • Public neighborhood and civic datasets, including walkability, transit access, and publicly reported local statistics

An advertised asking rent is a price the property owner has published to the entire market. It is not confidential, and a competing owner can already see it simply by looking at the listing.

Licensed third-party data. We license data from established third-party providers to supplement public sources. We require our providers to represent that the data they supply to us is not sourced from confidential rent rolls, property management system integrations, or other operational data contributed by landlords in exchange for pricing services. We review provider sourcing before onboarding and on an ongoing basis. If a provider cannot substantiate the sourcing of a dataset, we do not use that dataset.

Information about your own property, from you. When you request a report, you tell us about the specific property being valued. We use that information to produce your report and to make it more accurate for your property. If you are an owner or property manager and you tell us what a unit currently rents for, that figure is used to inform the report for that unit. It is not added to the data used to estimate rents for other people's properties.

Rent information reported by renters. Renters who use Inktrue tell us what they currently pay. This information does inform our broader model. We treat this differently from landlord-supplied rent information for a specific reason. The conduct these laws address is coordination among competitors, and the definitions turn on information collected from property owners and managers. A renter is not a property owner, a property manager, or a competitor of the landlord whose unit is being valued. Information moving from renters into a model and back out to the market does not create an exchange among competing sellers, which is the mechanism the law describes.

Renter-reported rent is handled under our Privacy Policy and is never associated with an identifiable renter in any report or dataset we produce or provide.

What we never ingest

We do not collect, purchase, license, accept, or ingest the following from landlords, property managers, or their systems, and our data pipeline is built to reject these categories rather than merely to avoid requesting them:

  • Executed rents from landlords, for use in valuing other parties' properties. See the partition rule below for how owner-supplied rent figures are handled.
  • Concession data across properties or portfolios: free months, waived fees, move-in incentives, or other off-list terms.
  • Occupancy and vacancy data from rent rolls or property management systems.
  • Lease expiration and renewal schedules. We do not know, and do not want to know, when any landlord's leases come up.
  • Forward availability. We do not track which units are becoming vacant, when, or in what quantity.
  • Renewal rates, retention rates, or turnover data at the property or portfolio level.
  • Direct integrations with property management systems that would transmit unit-level operational data to us.

Prices, supply levels, and lease dates are the three input categories the law names. We do not collect any of them from multiple owners.

We will not build a product feature that requires any of the above, and we will decline commercial arrangements that are contingent on providing them.

The partition rule

Owner-supplied and property-manager-supplied rent figures are tagged at the point of collection with the role of the person who supplied them. Records tagged as owner-supplied or manager-supplied are used to inform the report for that specific property, retained under our Privacy Policy and standard retention terms, and excluded from the data used to train or calibrate estimates delivered to any other user.

This exclusion is enforced in our data pipeline as a hard filter, not as an internal guideline. Records lacking a source tag do not enter our estimation data at all.

The partition rule is the operational mechanism behind the commitment in Inktrue does not perform a coordinating function. It is the reason we can state that our inputs do not come from two or more unaffiliated property owners.

Limits on what our product does

Data sourcing is only half of the question. What a pricing tool tells you to do matters as much as what it knows. Inktrue is constrained on the output side as well. Inktrue does not and will not:

  • Set a price floor or recommend against reducing rent. Our reports contain no mechanism that discourages, flags, or tracks price decreases.
  • Recommend occupancy targets. We do not tell you what vacancy rate to hold or how to manage supply.
  • Recommend lease terms, renewal terms, or lease timing as a coordination strategy.
  • Reprice dynamically. A report is a dated estimate produced at a point in time. It does not update itself, push new numbers, or run on a schedule.
  • Track adherence. We do not monitor whether you priced at, above, or below our estimate, and we have no mechanism to encourage you to follow it.
  • Coordinate across users. No Inktrue user is informed of, prompted by, or influenced by another user's pricing decisions.

An Inktrue report is a document. You read it and you decide. There is no loop.

Your audit record

Every Inktrue report is issued with a record that includes the report identifier, the date of issue, the model version used, and the classes of data that informed the estimate.

This record exists so that a property owner can demonstrate, after the fact, how a price was arrived at: from a dated estimate built on documented data classes, produced independently, without reference to any competitor's confidential information. We retain this record and can reproduce it on request.

What this document is not

This is a description of our engineering and data practices. It is not legal advice, and it is not a determination that any particular use of Inktrue complies with the law in your jurisdiction.

Laws governing rent pricing software vary substantially by state and by city, and several are new, recently amended, or subject to pending litigation. Definitions differ between jurisdictions, and some questions of interpretation have not yet been decided by any court. Underlying antitrust law also applies in every state, including states that have not passed a specific statute. Whether and how you may use any pricing tool, including ours, is a question for your own counsel and depends on where your property is located.

We publish this policy so that you and your advisors have the specific facts needed to make that assessment.

Changes to this policy

When our data sources or product constraints change, we update this document and retain prior versions so the history is inspectable.

The commitments in Inktrue does not perform a coordinating function, What we never ingest, and Limits on what our product does are intended to be permanent. We will not narrow them silently. Any change to them will be announced to active users in advance, with the prior version left available for comparison.

Contact

If you have questions about this policy, please contact us at admin@inktrue.com, Inoak Chapman Street, LLC.

This document supplements and does not replace the Inktrue Terms of Use and Privacy Policy. Where this document describes how personal information is collected, retained, or used, the Privacy Policy governs.

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