This Privacy Policy describes how The Real Brokerage, Inc. collects and uses Personal Data through our Website, mobile applications, email, text, and other electronic communications.

The Real Brokerage Inc. and its subsidiaries, including, but not limited to, Real Broker, LLC; Real Brokerage Technologies, Inc.; Real Broker AZ, LLC; Real Broker NY, LLC; Real Broker CT, LLC; Real Broker MA, LLC; Real Broker NH, LLC; Real Broker Commercial, LLC; Real Broker NE, LLC; Real Broker AB Ltd.; Real Broker B.C. Ltd.; Real Broker Ontario Ltd.; and Real Broker Manitoba Ltd. (collectively “Company,” or “we,” “our,” or “us”) respect your privacy, and we are committed to protecting it through our compliance with this policy.

This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from individual consumers, business representatives, real estate agents, and website visitors who visit or use our website located at www.joinreal.com (our “Website”) or any of our related mobile applications (our “App”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. For purposes of this Privacy Policy, our Website, App and all related services and functionality that we provide or make available through them are referred to as our “Digital Services”.

This policy applies to information we collect:

• on our Digital Services; in email, text, and other electronic messages between you and our Digital Services; 
• when you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by Company or any third party;
• any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Digital Services.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy, referenced below). Your continued use of our Digital Services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.  

We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.

Generally
We collect several types of information from and about users of our Digital Services, specifically information:

• by which you may be personally identified, such as name, postal address, billing address, shipping address, e-mail address, home, work, and mobile telephone numbers, date of birth, credit or debit card number (for payment purposes only), and/or real estate agent licensure information;
• that is about you but individually does not directly identify you, such as traffic data, logs, referring/exit pages, date and time of your visit to or use of our Digital Services, error information, clickstream data, and other communication data and the resources that you access and use on or through our Digital Services; or
• about your Internet connection, the equipment you use to access or use our Digital Services and usage details.

Collectively, we refer to this information in this policy as “Personal Data.”

We collect this information:

• directly from you when you provide it to us or communicate with us;
• automatically as you navigate through or use our Digital Services. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, pixels tags and other tracking technologies; and
• from third parties, for example, data aggregators and our business partners.

Information You Provide to Us
The Personal Data we collect is:

• Information that you provide by filling in forms on our Digital Services. This includes information provided at the time of registering to use our Digital Services, using our services or other services available through the Digital Services, purchasing products, or requesting further services. We may also ask you for information when you report a problem with our Digital Services;
• Records and copies of your correspondence with us, including your email address, email content, phone number, and recordings and transcriptions of phone calls with us;
• Your responses to surveys that we might ask you to complete for research, development and marketing purposes; and
• Details of transactions, including electronic signature transactions, you carry out through our Digital Services and/or of the fulfillment of your orders or services. You may be required to provide financial information before placing an order or requesting certain orders or services through our Digital Services.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Digital Services or transmitted to other users of the Digital Services or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Digital Services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Beneficiary Information. You have the ability to designate a beneficiary for revenue share amounts we owe to you. If you provide beneficiary information, you represent and warrant to us that you have the legal right and authorization, through consent or otherwise, to provide the beneficiary’s personal information to us.

Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Digital Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns. For example, we collect, record and store information about your activity when you access and use our Digital Services, the Internet, and other online activity information, such as browsing history, search history, and information regarding your interaction with our Digital Services and other websites. We use various technologies to collect and store location information, including cookies, pixels or pixel tags, local storage, such as browser web storage or application data caches, databases, session recording and replay technology, and server logs.

• Usage Details. Details of your visits to our Digital Services, such as traffic data, location, logs, referring/exit pages, date and time of your visit to or use of our Digital Services, error information, clickstream data, and other communication data and the resources that you access and use on or in the Digital Services; and
• Device Information. Information about your computer, mobile device, and Internet connection, specifically your IP address, operating system, browser type, and App version information.
• Location Data. Information about your location collected through Geolocation technology.

The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Digital Services and to deliver a better and more personalized service by enabling us to:

• estimate our audience size and usage patterns;
• improve our product and services offering;
• store information about your preferences, allowing us to customize our Digital Services according to your individual interests;
• recognize you when you return to our Digital Services.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). We and our service providers may use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Digital Services through your computer or mobile device. A cookie is a small file or piece of data sent from a website and stored on the hard drive of your computer or mobile device. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting you may be unable to access or use certain parts of our Digital Services. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website or use our App.
• Pixels and Web Beacons. Pages on our Digital Services, or our e-mails, may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related Digital Services statistics (for example, recording the popularity of certain Digital Services content and verifying system and server integrity).

Google Analytics. We may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of our Website. Google Analytics uses “cookies”, which are text files placed on your computer, to help our Website analyze how users use the site. You can find out more about how Google uses data when you visit our Website by visiting “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google’s website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.

Intercom. We may use Intercom, a web analytics service provided by Intercom, Inc. (“Intercom”) to collect certain information relating to your use of our Website. Intercom uses “cookies”, which are text files placed on your computer, to help our Website analyze how users use the site. You can find out more about how Intercom uses data when you visit our Website by visiting https://www.intercom.com/legal/privacy. We may also use Intercom to provide advertising features or other advertising networks to provide you with interest-based advertising based on your online activity.

We use information that we collect about you or that you provide to us, including any Personal Data:

• to provide our Website and its functionality, contents and services to;
• to provide our App and its functionality, contents and services;
• to provide our products and services to you, and any features of the Digital Services that you use, including features that make use of artificial intelligence and machine learning technologies;
• to provide you with information, products, or services that you request from us or that may be of interest to you;
• to process, fulfill, support, and administer transactions and orders for products and services ordered by you;
• to personalize your experience with our Digital Services and to deliver content and product and service offerings relevant to your interests;
• to market our financial products and services, such as corporate charge cards and debit cards;
• to determine your eligibility for our financial products and services, such as corporate charge cards and debit cards;
• to provide personalized and interest-based advertising;
• to provide you with notices about your Company account;
• to contact you in response to a request;
• to fulfill any other purpose for which you provide it;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• to enforce our financial partners’ rights under their cardholder agreements with you;
• to notify you about changes to our Digital Services or any products or services we offer or provide though them;
• to develop and improve our products and services, including to test and monitor the performance of product and service features, and to analyze and improve our business operations;
• in any other way we may describe when you provide the information; and
• for any other purpose with your consent.
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We may also use your information to contact you about goods and services that may be of interest to you, including through newsletters. If you wish to opt-out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications or by visiting your Account Preferences page. For more information, see Choices About How We Use and Disclose Your Information, referenced below.

We do not share, sell, share, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect or you provide as described in this privacy policy:

• to affiliates, contractors, service providers, and other third parties we use to support our business. The services provided by these organizations include providing IT and infrastructure support services, advertising, financial services, marketing, and payment processing services.
• to advertising and marketing partners such as Facebook, Instagram, Google and other advertising networks may receive and use your Personal Data to assist us with our advertising and marketing efforts.
• to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Company about our Digital Services users are among the assets transferred;
• to fulfill the purpose for which you provide it;
• for any other purpose disclosed by us when you provide the information;
• with your consent.

We may also disclose your Personal Data:

• to comply with any court order, law, subpoena, or legal process, including to respond to any government or regulatory request;
• to affiliates and third parties to market or advertise their products or services to you if you have not opted out of these disclosures. This type of sharing may be deemed a “sale” or “share” of Personal Data under some laws or jurisdictions. For example, Facebook, Instagram, Google and other advertising networks may have the ability to use your Personal Data for their own marketing, advertising or business purposes. For more information about your opt-out rights, see Choices About How We Use and Disclose Your Information, referenced below;
• to enforce or apply our Terms of Use, located at https://www.joinreal.com/page/legal, and other agreements, including for billing and collection purposes; and
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We offer real estate agents’ businesses financial products and services from our financial institution partners, such as a corporate charge card or debit card (collectively, “Financial Products”), to enable the business to purchase goods and services for a commercial purpose and conduct other financial activities. This section describes how we collect, use, and disclose Personal Data in connection with businesses’ applications for and use of the Financial Products.

• Information Businesses Provide Us. To obtain a Financial Product, the business (“you”, “your”) will need to submit an application that contains information to assist us in the underwriting process. The information you provide will include contact information (such as your name, phone number, and email and mailing addresses), financial information about your business (such as your bank account and routing numbers, account balances, business revenue and expected revenue, and credit history), and personal, professional, and financial information about your individual business principals. When you or your business principals use the Financial Products, we will also collect information about your transactions (such as information associated with your purchases, bill payments, reimbursements, and card transactions), as well as receipt and invoice data.
• Information We Obtain from Other Sources. To complete the underwriting process, we will obtain financial information from our financial institution partners (such as the bank issuing your card or other Financial Product), credit reporting agencies, and other entities that provide or support delivery of financial services. We may also receive information from identity verification, fraud prevention, and compliance monitoring providers to help us supplement our understanding of your business and prevent fraud, as well as from referrals and reward partners that we engage for our referral and rewards programs. If you link your card or other Financial Product to a business or personal bank account, we may receive bank account information about the linked account, such as the bank routing and account numbers and account balance. We may continue to access and receive bank account data from connected accounts until you disconnect them.
• Information Use. We will only use the information we collect in connection with the Financial Products to provide our services, determine eligibility for and facilitate our rewards programs, conduct internal auditing and reporting, maintain security and fraud prevention, and comply with our legal obligations.
• Information Disclosure. We will disclose the information we collect in connection with a Financial Product to our financial partners so that they can determine your eligibility to receive and use a Financial Product, to determine eligibility for and facilitate rewards programs, and to support their customer identification, risk, and compliance programs. We may also disclose this information to our vendors that help us provide our services, and to law enforcement and other third parties to comply with our legal obligations.

We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for our advertising to you, and other targeted advertising.

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. These third parties may aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

• Tracking Technologies and Advertising. You can set your browser or operating system to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Digital Services may then be inaccessible or not function properly.
• Promotional Offers from Company. If you do not wish to have your email address used by Company to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us or logging onto your Account Preferences page. This opt out does not apply to information provided to Company as a result of a product purchase, or your use of our services.
• Disclosure of Your Information to Affiliates and Third Parties. If you wish to unsubscribe from affiliates and third parties’ promotions, you can do so by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from them. If you wish to opt-out of such sharing, please change your preferences in your Account Preferences page or email us support@therealbrokerage.com.
• Interest-Based Targeted Advertising. We may use your Personal Data to provide interest-based advertisements from us and that are customized to your particular preferences, including for companies that are not affiliated with us. We partner with third party advertising networks that collect IP addresses, unique device identifiers, browser type, operating system, time zone, country, referring pages, and other information through the use of cookies, pixel tags, and server logs on our Digital Services. They use this information to provide you with interest-based advertisements that are customized to your particular preferences, including for companies that are not affiliated with us.

You may see these interest-based advertisements on our Digital Services, as well as on third party websites and apps, and across different devices you use. We may use this process to help us manage and improve the effectiveness of our marketing efforts. It also allows us to display ads to our users about Company after they leave our Digital Services, and to track users after they see or click on an advertisement, keep track of users who access our Digital Services or advertisements from different devices, and better provide advertisements to our target audiences. The data collected through these tracking technologies is also saved and processed by our advertising and marketing service provider partners.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info).

In addition to the disclosures and rights set forth elsewhere in this Policy, you and other users may have certain rights based on applicable state law, for example, the California Consumer Privacy Act, as updated by the California Privacy Rights Act (CCPA). Other states have passed consumer privacy laws that may be applicable to Real and your use of this Site. These supplemental disclosures and rights apply to you and your use of our Digital Services to the extent applicable state law applies to Real and your use of our Digital Services. Please contact us if you have any questions regarding your rights under applicable state law.

Categories of Personal Information Company Collects
As described in more detail in other areas of our Privacy Policy, we collect and/or disclose Personal Data (termed “Personal Information” in the CCPA) about you when you visit use our Digital Services, including information about you that you provide to us, and information that we automatically collect from you or your computer or device as you use our Digital Services. Please refer to Information We Collect About You and How We Collect It, referenced herein, for additional information and details.

Personal information does not include information that is: (a) publicly available information from government records; (b) de-identified or aggregated consumer information; or (c) certain information excluded from the scope of applicable state law (e.g., PHI covered under HIPAA and medical information may be covered under other state laws).

Categories of Sources from which Company has collected Personal Information
As described in more detail elsewhere in this Policy, we collect Personal Information directly from you, for example when you provide it to us, when you contact us through our Digital Services, when you create a Company account; and indirectly from you automatically through your computer or device as you use our Digital Services. We may also collect Personal Information about you from our advertising partners and service providers.

Use of Personal Information
We may use or disclose the personal information we collect for our business purposes described elsewhere in this Privacy Policy (for example, please refer to “How We Use Your Information” and “Disclosure of Your Information”).

Disclosures of Personal Information for Business Purposes:
As described in more detail elsewhere in this Policy, we may disclose your Personal Information for our business purposes, such as your contact information, other information you have provided to us and unique identifiers that identify you to us or to our service providers, such as companies that assist us with marketing and advertising. Please refer to Information We Collect About You and How We Collect It, referenced herein for additional information and details.

We disclose your Personal Information to certain third parties such as our vendors, business partners, service providers, including companies that assist us with marketing and advertising. For additional information please refer to “How We Use Your Information” and “Disclosure of Your Information”).

Access Request Rights
You may have the right to request that the Company disclose certain information to you about our collection and use of your Personal Information for the above business and commercial purposes. To submit an access request, see Exercising Access and Deletion Rights, referenced herein. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you.
• If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
• sales, identifying the Personal Information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights
You may have the right to request that the Company delete your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless certain exceptions apply.

Correction Request Rights
You may have the right to ask us to correct Personal Information that is inaccurate or out of date. You may also be able to review and change your Personal Information by logging into the Digital Service and visiting your Account Preferences page.

Right to Opt Out of Selling or Sharing Personal Information for Targeted Advertising
As explained in the Interest-Based Targeted Advertising section above, we may share Personal Information with advertising partners that display targeted advertisements to users around the web, including through the use of cookies and other similar technologies on our Websites. This may qualify as a “sale” or “share” of Personal Information under applicable privacy laws. You can opt out of sharing for these purposes by clicking Your Privacy Choices on the footer of our website or contacting us as described below.

Exporting Data
If you need to export or obtain a copy of your data, please let us know and we will assist you with your request. We retain the data we collect for different periods of time depending on what it is, how we use it and applicable legal requirements. We may retain some data for longer periods of time than other data when necessary for legitimate business or legal purposes, such as security, fraud and abuse prevention, or financial record-keeping.

Exercising Access, Correction, and Deletion Rights
To exercise the access, correction, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 646-859-2368 (United States) or 782-820-4098 (Canada).
• Emailing us at support@therealbrokerage.com.

Only you, or your legal representative authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Please note that applicable law limits your rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.

Non-Discrimination
We will not discriminate against you for exercising any of your rights under applicable state law. Unless permitted by applicable 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 or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.