Privacy Notice

1. The kinds of information we collect

Information You Provide Us or That We Collect About You. We collect information that you provide to us and other content, images and information when you access our Services, including when you complete webforms on www.mainstay.io; create an account with us; communicate with us about our Services via comments, direct message, telephone, text or e-mail; or respond to one of our surveys; visit or tour a property we have listed; sign in at an open house or use a self-guided touring system; meet or speak with one of our licensed agents; or give us an offer, a pre-qualification, or transaction paperwork.

Categories of personal information that you may provide to us or that we may collect include:

• Your name and email address;
• Your telephone number;
• Your account log-in details (e.g. email/username, password);
• Homes you view through our Services;
• Billing information (e.g. billing name and address and credit/debit card information).
• Reviews or comments you leave on our Services or on other public websites or services associated with us, such as social networking platforms.
• Your mailing address, and the address of a home you occupy or are interested in buying;
• Information about your interest in and ability to buy a home, including the price range you are considering, how you intend to pay, pre-approval or proof-of-funds documentation, and your lender’s identity if you choose to share it;
• Government-issued identification, such as a driver’s license or passport, where we need to verify who you are — for example, to give you access to a property for a self-guided tour, to confirm your identity before closing, or to meet identity-verification and sanctions-screening obligations that apply to us;
• The contents of your communications with us, including notes our agents make about your search, and recordings or transcripts of telephone calls where we tell you at the start of the call that it is being recorded;
• Information about your household that is relevant to a transaction, such as how many people will live in the home or a request for an accommodation during a showing.

Information We Receive About Residents from the Owner of a Home. Our Owner Clients are owner-operators of residential real estate. When one of them decides to sell a home and requests that we contact the person living there to determine if they may want to buy it, the owner gives us four things so that we can get in touch: your name, your email address, your telephone number, the address of the home you occupy, and your lease-end date.

We did not collect this information from you, so we want to be clear about how we handle it. We do not ask for, and we instruct owners not to send us, resident screening reports, credit reports, background checks, or rent payment histories. If we receive information like that anyway, we delete it and we do not use it. You are under no obligation to respond to us. Whether you talk with us, tour a home, or make an offer – or engage one of our brokerages to represent you -- is entirely your choice, and it does not affect your tenancy -- the owner of the home, not Mainstay, sets your lease terms.

Documentation That You Are Able to Buy. Before a purchase can move forward, you will need to show that you are financially qualified to purchase the home (usually in the form of a lender pre-approval letter from a lender, and/or bank statement). We will tell you that this is required. We may work with partner lenders from time to time and may tell you about them, but you are free to use any lender you choose. We do not pay or receive anything of value to or from any lender, including our partner lenders, for sending business their way. We may receive valuable benefits from use of our affiliate title company or other settlement service provider; we will provide you required disclosures in each such case.

If you give us a bank statement, we do not need your account numbers, and we will endeavor to remove them before the document goes into your transaction file. We keep the redacted copy with the rest of the transaction records and do not leave the original sitting in email or text.

Information We Collect Through Our Property Platform. Mainstay Labs Inc. operates a software platform that collects and organizes property records for owners of residential rental properties and their authorized users (“Platform Users”) and uses them to surface insights, opportunities, and tasks (the “Platform”). When you use the Platform, we collect:

• Account and contact information, such as name, email address, phone number, mailing address, business or entity name, password, and the users you invite;
• Property information, such as property addresses, parcel numbers, ownership entity, and other property details you enter;
• Documents, images, and emails you upload or forward to the Platform (“Platform Content”) and the information they contain, which may include (among other things) leases and tenant names, contact details, rent, and security deposit information; bills, invoices, receipts, and utility account information; property tax, assessment, and payment information; HOA, municipal, code, and permit information; purchase, closing, title, and loan information; insurance policy information; vendor, contractor, and inspector names and contact details; warranty, model, and serial numbers; and photographs of properties, systems, and equipment;
• When you forward or send documents to your Platform email address, the email message, attachments, sender and recipient addresses, subject line, date and time, and related header metadata; and
• Questions you ask in the Platform, feedback, survey responses, and support communications.

Platform Information from Other Sources. We may obtain information about properties from public records (such as county assessor, recorder, tax collector, permit, and code enforcement records), from third-party real estate, rent, and property data providers, and from services Platform Users choose to connect. This information may include ownership records, owner names and mailing addresses, assessment and tax history, homeowners association information, sale history, and property characteristics.

Information We Generate. We generate extracted data fields, document classifications, summaries, property records, answers to questions, and insights from the information described above, including identified opportunities to reduce costs or increase income, recommendations, reminders, and task lists (“Insights”).

Sensitive Information in Platform Documents. We ask Platform Users not to submit, and to redact before submitting, Social Security numbers, government identification numbers, full financial account or card numbers, consumer or tenant screening reports, background checks, and health information, but we cannot guarantee they will honor these requests in each instance. If such information is included in a document, it may be processed as part of that document.

Individuals Named in Platform Documents. Platform Content may include information about tenants, occupants, guarantors, co-owners, sellers, lenders’ contacts, HOA representatives, property managers, vendors, contractors, inspectors, and other individuals (“Third-Party Individuals”). When we process Third-Party Individuals’ information contained in Platform Content, we do so on behalf of, and at the direction of, the Platform User in order to provide the Platform, and the Platform User is responsible for having a lawful basis and providing any required notices. Where applicable law treats us as a “service provider” or “processor” for that information, we process it in accordance with the Platform User’s instructions and applicable law, except as permitted by law (including to create de-identified data).

Platform Information Is Not Used for Resident Outreach. Our brokerages do not use information in a Platform User’s account to identify, locate, or contact residents about buying or selling a home. Resident outreach uses only the information an Owner Client provides to our brokerages for that specific purpose, as described above.

Information We Collect from Your Device. We may collect the following information, which may or may not constitute personal information, from the device that you use to access our Site or the Services:

• Device attributes such as the operating system, hardware and software versions, battery level, signal strength, bandwidth, available storage space, browser type, app and file names and types, and plugins;
• Information about operations and behaviors performed on the device, such as clicks, scrolls, mouse movements (which can help distinguish humans from bots), keystrokes, whether a window is in the foreground or background, and other information about your browsing session;
• Identifiers unique to you, your device, or your account(s), such as device IDs, cookie IDs, and advertising IDs;
• Information you allow us to receive through device settings you turn on, such as access to your GPS location;
• Network and connection information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, and IP address; and
• Data from cookies, tags, pixels, web beacons, and log files stored on your device, including cookie IDs, page views, how often you visit our Services, and links you click on.

Cookies, Analytics, and Session Recording. We and the vendors who work for us use cookies, tags, pixels, and similar technologies on our website. They keep you signed in, remember your preferences, tell us how the site is used and which pages people find, and help us find and fix errors. Some of these technologies are set by third parties, such as Google Analytics, which helps us understand traffic on our website. We may also allow advertising partners to set cookies and pixels on our website so that we can show you ads for our Services on other websites and measure their effectiveness, as described in Sections 2 and 4. We do not use information we receive about residents from an Owner Client, or sensitive information, for advertising.

You can block or delete cookies through your browser settings, though parts of the site may not work as well if you do.

If You Sign Documents with Us Electronically. Our electronic signature tool uses a product analytics service to see that sign-up and signing are working. That service receives your email address and, if something goes wrong, the technical details of the error. It works for us under contract and cannot use your information for its own purposes.

Session Recording on the Tools Our Staff Use. The internal applications our agents and staff use to operate our Services can record what happens on screen during a session, so that we can diagnose problems and see where the software can be improved. You do not use these applications, but your information appears in them, which means it can appear in a recording (e.g. your name and address, the terms of an offer, or a document displayed on screen) – although your credentials and passwords are masked. These recordings are held by a monitoring provider that works for us under contract, may not use them for its own purposes, and must delete them when we ask. Access is limited to the people who need it to fix the software. Our Services do not respond to the legacy Do Not Track browser header. Universal opt-out preference signals, such as Global Privacy Control (“GPC”) are explained in further detail in Section 4.

2. How we use this information

To Provide Our Services. We use the information that we collect about you to deliver our Services. We may make use of technological advances, including but not limited to artificial intelligence (AI) and/or machine learning (ML), in order to build, personalize, and improve our Services.

We do not use the sensitive information described in Section 1 (e.g. government issued identification, or financial qualification documentation) to train AI or ML models. We also do not use information about residents or consumer buyers to train models that we make available to our business customers.

To Complete a Real Estate Transaction. When you contact us about a home, tour a property, negotiate, or buy, we use your information to respond to you, schedule and provide access to properties, verify who you are, evaluate and communicate offers, prepare and deliver the disclosures and agreements that real estate law requires, coordinate with the parties who close the transaction, and maintain the transaction file our licensing regulators require us to keep.

To Provide and Improve the Platform. We use Platform information, including Platform Content, to create and manage accounts; receive, store, classify, and file documents; extract data; build and maintain property records; enrich them with public-record, Brokerage information, and third-party data; answer questions; generate Insights; and provide reminders, notifications, and support. We also use it to analyze and improve the Platform, including by training, testing, and improving the models that power these features.

To Develop New Products and Services. We develop new features, products, and services using Aggregated Data, as described below, and, for Platform Content, as permitted by the agreements we have with Platform Users and applicable law.

To Contact Residents About an Opportunity to Buy. Where an Owner Client has given us your information as described in Section 1, we use it to contact you by mail, email, telephone, or text message about the opportunity to buy the home you live in, and to answer your questions if you decide to engage with us. Our agents send these messages individually about your potential transaction, and not about other products or services. We don’t use that information for any other marketing purpose. If you tell us you’d rather not hear from us, we’ll stop, and we’ll honor that across every channel we use (See Section 6).

To Report to the Owner on Your Offer. The Owner Client is our customer, and we keep it informed about the sale of its property. What we tell the owner about you is limited to what it needs to evaluate and respond to an offer on the home in question. If you engage one of our brokerages to represent you in a transaction opposite an Owner Client, we will disclose to the Owner Client only such information as and when is permitted by the agency agreement signed by you and the brokerage, as limited by applicable brokerage licensing laws, rules and regulations.

To Advertise Our Services. We may use information collected about you to provide you with relevant information about additional Services that the Company offers. Specifically, we may use information about how you interact with our Services, combined with information you provide us and information we collect from other sources, to serve you relevant advertising. We do not use information we receive about residents from an Owner Client, or sensitive information we collect in the course of a transaction, for advertising of any kind.

You may have additional choices available to you with regards to some online behavioral advertising cookies. Please visit the Digital Advertising Alliance at optout.aboutads.info or the Network Advertising Initiative at optout.networkadvertising.org for more information.

We may also allow third-party cookies on our website to assist in enhancing the website. For example, we allow Google to provide us with analytics on our website traffic. For more information about how to opt out of Google Analytics, you can visit tools.google.com/dlpage/gaoptout. For other privacy choices made available by Google, you can visit policies.google.com/technologies/ads.

To Do Market Research. We are constantly striving to improve our customer experience. We conduct research into all aspects of the home buying and selling process to try to identify ways to make it better. We may use partner companies to conduct surveys of willing participants who offer suggestions as to how we might improve our Services. We also aggregate and analyze information that we collect through our Services and from conversations with our customer service representatives to identify trends, which inform how we change and grow, as described in Aggregated and De-Identified Data below.

Property Analysis and Market Intelligence. We prepare comparative market analyses to price homes, and we publish market intelligence about the housing market. This work uses information about properties, including without limitation addresses, characteristics, listing and sale prices, and dates. It does not use your name, your email address, or your telephone number, and nothing that identifies you personally goes into a market intelligence product.

Aggregated and De-Identified Data. We create information from our Services, including Platform Content and Platform usage, that has been aggregated and/or de-identified so that it cannot reasonably be used to identify you, any individual, or any specific property address (“Aggregated Data”). Examples include regional rent, tax, insurance, HOA, utility, and maintenance cost benchmarks and equipment life statistics. We may use and disclose Aggregated Data for any lawful purpose, including to create, license, and sell insights, reports, and other products, and we may continue to use it after an account is closed. When we maintain de-identified information, we (a) take reasonable measures to ensure it cannot be associated with an individual or household, (b) publicly commit to maintain and use it in de-identified form and not attempt to re-identify it, except as permitted by law to test our de-identification processes, and (c) contractually require recipients not to re-identify it. Aggregated Data is not personal information and is not subject to the rights described in Section 9.

To Support Information Security and Debugging. We may use information about you and your use of the Services to detect security incidents, protect against malicious, fraudulent, or illegal activity, and improve the security of our Services. We may also use this information to debug our Services to identify and repair errors that impair existing intended functionality.

In Connection with a Dispute. We may use personal information to prosecute or defend against claims in court and other dispute resolution forums.

Uses of Device Information. We generally use this information for your convenience and to improve our Services. For instance, we may use it to: (i) remember your personal information so that you do not have to re-enter it; (ii) provide you with customized content and information, including advertising; (iii) monitor the effectiveness of our Services; (iv) monitor aggregate metrics such as total number of visitors, traffic, and usage patterns; or (v) diagnose or fix technology problems.

What We Don’t Do. Once a transaction closes, or once your inquiry ends without one, we stop using your information to market homes or services to you. After that, we keep identifiable information only to finish the transaction, to meet the recordkeeping obligations that apply to us as a licensed brokerage, and for the security, dispute, and legal purposes described in this notice, and we may use it to create Aggregated Data. Section 7 explains how long that is.

3. Why and how we disclose your information

At Your Direction. We may disclose your information when you specifically direct us to do so.

With Service Providers. We may disclose your information to service providers, including, but not limited to, payment processors, technology and infrastructure providers, digital communications services, commercial data and market research analysts, consumer report providers, auditors and accountants, physical site security providers, IT security and bug-fix partners, artificial intelligence (AI) and/or machine learning (ML) providers, optical character recognition and email processing providers, customer service providers, other partners, and other providers who perform services for and on our behalf. In a consumer transaction, those providers also include electronic signature and transaction-management platforms, showing and self-guided touring systems, our customer relationship management system, and providers of AI-based note-taking, transcription, or drafting tools. We require our service providers by contract to use your information only to perform services for us, and not for their own purposes. We require our AI and ML providers not to use your information or Platform Content to train their own general-purpose models.

With the Owner of the Home. In a transaction, Mainstay often represents the seller — the owner of the home. We give the owner what it needs to evaluate and respond to an offer: your name, the terms you have proposed, and confirmation that you are able to complete the purchase. We do not give the owner the confidential information you share with your own designated agent, as described below.

Who Is Responsible for Your Information. When Mainstay represents an Owner Client to sell a home, two companies hold information about you at different points, and privacy laws treat that difference as meaningful, so we want to be plain about it. The Owner Client decides, on its own, to run a program that offers you the chance to buy, and it decides to send us your name and contact details. For that decision and for everything the Owner Client does with your information in its own systems, the Owner Client is responsible, and you can ask the Owner Client directly about it. From the moment we receive your information, Mainstay is responsible for what Mainstay does with it (i.e. how we reach out, what we analyze, how long we keep it, and who we share it with) and we answer to you for that. There is a narrow set of work we do strictly on the Owner’s Client’s instructions, such as reporting the status of an offer back to it, and we do that under a contract that limits us to the Owner’s Client’s purposes. You do not need to sort out which of these applies before you ask us something. Contact us at the address in Section 10, and if a request belongs with the Owner Client rather than with us, we will tell you and pass it along.

With the Parties Who Close the Transaction. Title companies, escrow and settlement agents, closing attorneys, the lender you select, the insurance or home warranty providers you select, inspectors, appraisers, and county recording offices, as needed to complete and record the sale. Some of this information becomes part of the public record.

With Multiple Listing Services and Listing Websites. When a home goes under contract and closes, we report the transaction to the applicable multiple listing service (MLS), as the rules of our participation require. The MLS may distribute that information to its members and to public listing websites. For residential property, sale price and closing date are generally public information.

Designated Agency and Information Separation. Where Mainstay is the listing broker for the owner of a home, if you are an unrepresented buyer interested in one of those homes and you’d like representation, a separate licensed agent of our brokerage will be designated to represent you, under the designated agency arrangement your state recognizes. You’ll receive the agency disclosures your state requires before that representation begins.

Under that arrangement, what you share in confidence with your designated agent (i.e. the most you’re willing to pay, why you’re buying, your financial position, and how you want to negotiate, etc.) stays confidential to you, and the agent representing the owner is not permitted to look at it. Our written policy prohibits an agent on one side of a transaction from accessing the other side’s file, and access to our systems is logged and reviewable by our technology team.

Within Mainstay. If you are a customer of Mainstay Labs Inc. (for the Platform or otherwise) and request representation by Mainstay Brokerage LLC or Mainstay Brokerage Inc., your information will be shared with that brokerage for the purpose of providing the requested services. That may include Mainstay Labs Inc. sharing information with Mainstay Brokerage LLC or Mainstay Brokerage Inc., which may have a duty of disclosure of certain facts regarding a property to a buyer customer in a future transaction. In addition, your information is available to the people at Mainstay who need it to move your transaction forward. In our brokerage systems, that includes brokers, licensed agents, and related support functions. It also includes employees of Mainstay Labs Inc. who support a transaction, such as our technology and transaction support teams. Everyone with access is bound by the confidentiality rules described above, and access is logged.

Processing Outside the United States. We work with a business process outsourcing provider whose teams are located in foreign countries (currently including India and Mexico), engaged by Mainstay Labs Inc. Those teams support transaction and customer service work and may see your information in the course of it. They are contractually required to use it only to perform services for us, to protect it, to return or delete it when we ask, and not to use it to train artificial intelligence or machine learning models. If your information is transferred outside the United States, we remain responsible for it.

With Data Providers and Platform Users. We may send property addresses or parcel identifiers (but not Platform Content) to third-party data providers to retrieve property data for a Platform account. We disclose Platform Content to the users a Platform User invites to its account and to third parties a Platform User directs us to share with.

With Law Enforcement, Courts, or Government Agencies. We may disclose your information as necessary to respond to legal process or to regulatory authorities (e.g., pursuant to a subpoena, warrant, investigative demand from law enforcement, regulators or others, or national or international security letters); to investigate, prevent, or take action regarding suspected or actual illegal activities (including fraud or stalking), and security or technical issues; to respond to or participate in commercial disputes (e.g., lawsuits or investigations); or to protect against fraud, claims, or other liability or harm to you, us, or others.

Business Transfers. We may disclose your information in connection with an actual or proposed merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our business or assets, subject to customary confidentiality protections.

Affiliates. We may disclose your information to our current and future affiliates, consistent with this Privacy Notice.

4. Selling or sharing your data

The Company has not sold or shared (as those terms are defined under applicable law) your personal information in the past 12 months. The Company has no actual knowledge that it has sold or shared any personal information of consumers under 16 years of age.

We don’t sell personal information. We may allow advertising partners to set cookies and pixels on our website to show you ads for our Services, which some state laws treat as “sharing” personal information or “targeted advertising.” You can opt out as described below. We never use resident information we receive from an Owner Client, or sensitive information, for advertising, and we don’t sell or license consumer or resident information. Although we may work with partner lenders from time to time, we neither pay nor receive anything of value for referring you to a lender, title company, or other settlement service provider.

Universal Opt-Out Preference Signals. Some browsers and extensions can send a signal such as the Global Privacy Control (“GPC”), telling every website you visit not to sell or share your personal information. We treat a GPC signal as a request to opt out of sharing and targeted advertising for that browser or device, as applicable law requires. You can also opt out by sending an email to [email protected], or ask us anything about your information, or ask us to stop contacting you, using the address in Section 10 or the methods in Section 6.

5. How we protect your information

Safeguards. We use commercially reasonable physical, electronic, administrative, and procedural safeguards to preserve the integrity, confidentiality, and security of all personal information collected through the Site and the Services. However, no security measure, system, or control is infallible. Therefore, like all businesses, we cannot guarantee that our Site or Services are invulnerable to attack or misuse.

Identification Documents. Where we collect a government-issued identification document, we collect it for a single stated purpose, limit access to the people who need it, and dispose of it securely.

Wire Fraud. Real estate transactions are a frequent target of wire fraud, so please read this carefully. Mainstay will never send you wiring instructions by email, and will never ask you to change wiring instructions by email or text. If you receive wiring instructions, or a change to instructions you already have, and they appear to come from us or from a closing agent, call the office at a number you have verified independently before you send any money.

Your Role. You have a major role in the security and privacy of your own information. For example, you should not provide us with personal information that we do not request. Additionally, you are responsible for controlling access to any personal computing device through which your information may be stored or accessed. You are also responsible for safeguarding any passwords or other log-in credentials that may be used to access your information. We recommend that you log out of any account when you are done using it.

Third Parties. Please remember to review the privacy settings and security policies of third-party sites and services that you use. We are not responsible for the privacy or security measures of any third party.

Incident Response. In the event that the security of any personal information under our control is compromised, we will take reasonable steps to investigate and mitigate the situation, including, when appropriate, notifying those individuals whose information may have been compromised and taking other steps in accordance with applicable laws and regulations.

6. Opting out of our communications

If you wish to no longer be contacted by the Company, you may click on the unsubscribe links in our marketing emails and request removal from our mailer list at [email protected].

This applies to every way we might reach you, not just email. If you tell us you’d rather not be contacted about a home, either by replying to an email, telling one of our agents, writing to us, or saying so on the phone, we’ll record that and stop contacting you through every channel we use, including telephone, text message, direct mail, and in-person outreach.

A particular consent you may have given to the owner of your home, to a property manager, or to another company does not necessarily carry over to Mainstay. Where we need your permission to contact you a particular way, we’ll ask you for it.

7. Retention of your information

We keep your information only as long as we need it, and we don’t apply one period to everything.

The transaction file: seven years. If you enter into a transaction with us, we keep the transaction file for seven years after closing or, if the home is listed but never sells, seven years after the listing ends.

Calls, texts, and email: two years. Recordings of telephone calls, text message threads, and email correspondence that are not part of a transaction file are deleted two years after our last contact with you. If you ask us about a home and don’t go further, this is the period that applies to you.

Platform information. We retain Platform information for as long as the Platform account is active and as needed to provide the Platform. After a Platform User asks us to delete it, we will delete or de-identify identifiable Platform Content within a commercially reasonable period of time, except that we may retain (a) backup copies until they are overwritten in the ordinary course; (b) information we must keep to comply with legal obligations, resolve disputes, or enforce our agreements; and (c) Aggregated Data.

We may keep information longer where we need it to resolve a dispute, defend a claim, complete an audit, or meet another legal obligation.

Because those are legal obligations, they can limit our ability to honor a deletion request. If you ask us to delete information we’re required to keep, we’ll tell you what we’re keeping and why, and we’ll delete the rest.

8. Fair housing and automated decisions

Fair Housing. Mainstay complies with the Fair Housing Act and with applicable state and local fair housing laws. We do not use race, color, religion, national origin, sex, sexual orientation, gender identity, familial status, disability, or any other characteristic protected by law to decide who hears about a home, who gets to see one, or how an offer is handled.

Automated Decisions. We do not use automated processing or profiling to make decisions about you that produce legal or similarly significant effects, and we do not use it to decide who is offered a home or on what terms. A licensed person makes those decisions. Where we use software to organize or prioritize our own outreach, it does not use protected characteristics, and it does not set the price, terms, or availability of a home.

Accommodations. If you need an accommodation to tour a home or to take part in a transaction, tell us and we’ll work with you. We use that information only to provide the accommodation.

9. Supplemental state notice (for California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia residents)

Our Collection of Personal Information. We may collect the following categories of personal information:

• Personal identifiers, such as your name and email address, postal address, telephone number, and, where required, a government-issued identification number
• Internet or other electronic activity information, such as browsing history and information related to your interaction with an internet website application
• Geolocation data, such as physical location and your account log-in
• Commercial information, such as the homes you have viewed, toured, or made offers on
• Financial information, such as how you intend to pay, pre-approval or proof-of-funds documentation, and payment information
• Audio and electronic information, such as recordings or transcripts of calls we have told you are recorded
• Characteristics of protected classifications, only where you volunteer them or where they appear in information an owner gives us; we do not use these in any decision about you
• Professional or commercial information contained in Platform Content, such as lease, rent, property, insurance, loan, and transaction information
• Sensitive personal information, consisting of government-issued identification numbers, financial account information, account log-in credentials and approximate geolocation (from IP address).

Categories of sources from which we collect these categories of personal information about you:

We collect personal information from you directly; from your device when you use our Services; from our Owner Clients, in the case of residents of homes they own; from Platform Users, in the case of Third-Party Individuals named in Platform Content; from other parties to a transaction, such as your lender, a title or escrow agent, or a cooperating broker; from multiple listing services, public records, and third-party property data providers; and from service providers acting on our behalf.

Categories of third parties to which we may disclose these categories of personal information:

We may disclose the categories of personal information listed above to the categories of third parties described above in Section 3 of this Privacy Notice.

We have disclosed these categories of personal information above for a range of operational purposes, including for business purposes such as:

• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
• Helping to ensure security and integrity to the extent the use of personal information is reasonably necessary and proportionate for these purposes.
• Debugging to identify and repair errors that impair existing intended functionality.
• Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, providing analytic services, providing storage, or providing similar services on behalf of the business.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device.
• Completing a real estate transaction you have asked us to help with, and meeting the disclosure, recordkeeping, and supervision obligations that apply to us as a licensed real estate brokerage.

We do not sell (as that term is defined under applicable state law) your personal information or sensitive personal information. We may share personal information collected through cookies and pixels on our website for targeted advertising, as described in Section 4, and you may opt out of that sharing. We have no actual knowledge that we have sold or shared any personal information of consumers under 16 years of age. We do not use sensitive personal information for targeted advertising, and we do not use personal information for profiling in furtherance of decisions that produce legal or similarly significant effects (as those terms are defined under applicable state law). We do not process sensitive personal information for any purpose other than those described in this notice, and we collect it only where a specific legal or transactional requirement calls for it.

Notice at Collection. Where required, we give you a short notice at or before the point we collect your personal information – on our webforms, on property sign-in and touring systems, and in the first letter or email we send you – identifying the categories we collect, why, whether we sell or share it, and how long we keep it. That short notice links to this Privacy Notice.

Your State Specific Rights. In addition to Company’s general privacy policies, users that are residents of the states listed at the beginning of this section may have specific rights. They include:

• The right to request that we disclose what personal information we collect, use, and share about you during the preceding 12 months free of charge, unless subject to a legal exception.
• The right to opt-out of sale or sharing to third parties of your personal information, or targeted advertising.
• The right to request that we correct inaccurate personal information.
• The right to request that we delete personal information collected or maintained by us about you, unless subject to a legal exception.
• The right to know what personal information or sensitive personal information is sold or shared and to whom.
• The right to limit use and disclosure of sensitive personal information.
• The right to designate an authorized agent to make a request under state law on your behalf.
• The right to be notified that we collect personal information about you, and the purposes for which the information will be used.
• The right to obtain a copy of your personal information in a portable, readily usable format.
• The right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.
• The right to appeal a decision we make about your request.

Non-Discrimination. We will not discriminate against you for exercising your state specific privacy rights. Unless permitted by law, we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level of quality of goods or services; or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Retention of Your Information. We retain each category of personal information and sensitive personal information we collect for the periods, or using the criteria, described in Section 7, including the transaction file, communications, and Platform information periods, and the recordkeeping obligations that apply to us as a licensed real estate brokerage, which can limit a deletion request.

Third-Party Individuals. If you are a tenant or other individual whose information is contained in a Platform User’s documents, you may direct your request to that Platform User. If you contact us, we will forward your request to the relevant Platform User where we can identify them, or respond as required by law.

How to Make a Privacy Request. You may exercise any of your rights outlined above by emailing [email protected]. We’ll acknowledge your request promptly and respond within 45 days. If we need an extension that your state’s law allows, we’ll tell you before the first 45 days are up.

Only you or a duly authorized agent (if permitted by state law) may make a request on your behalf. If you are an authorized agent making a request on behalf of a resident of a state where it is permitted, please email us at [email protected]. To process your request, our team may require identity verification. In some instances, we may decline to honor your request where an exception under law applies.

You have the right to make a free request twice during any twelve-month period. The request must:

• Provide sufficient information for us to reasonably verify that you are the person, or an authorized representative of the person, about whom we collected the personal information or sensitive personal information; and
• Describe your request with sufficient detail for us to properly understand, evaluate, and respond to the request.

Submitting a request does not require you to create an account with us. However, for your safety and the safety of your information, we cannot fulfill a request to provide or delete personal information or sensitive personal information if we cannot verify your identity or authority to make the request and confirm that the personal information or sensitive personal information relates to you or an individual for whom you are an authorized agent. We may require additional verification before deleting or disclosing particularly sensitive information. We will only use the verification information you provide for the purpose of verifying your identity or authority to make the request.

We do not charge you a fee to process or respond to your verifiable consumer request, unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

You may have the right to appeal our decision with regard to a request. You can do so by contacting us at [email protected].

10. Children

Our Services are not directed to children under 18. We do not knowingly collect personal information directly from children. If you believe a child has provided us with personal information, contact us and we will delete it.

11. Third-party links and services

Our Services may contain links to, or let you connect, third-party websites and services, including partner lenders. We are not responsible for their privacy practices, and their own policies govern information you provide to them.

12. Updates and questions

This policy is updated regularly. We will promptly make any changes available here. Changes will be effective as soon as the updated policy is posted unless otherwise stated. If you have a question about this policy you may contact us at [email protected].