Privacy Policy

1. Introduction

Pocket Software, LLC ("we," "our," or "us") operates the RE:Partner platform, including the RE:Agent and RE:Buyer applications (mobile and web) and the repartner.ai website (collectively, the "Platform"). This Privacy Policy describes how we collect, use, disclose, and protect your information when you access or use the Platform.

This Privacy Policy is incorporated by reference into our Terms of Service and complies with the Colorado Privacy Act (CPA) and other applicable data protection laws.

By using the Platform, you acknowledge that you have read and understood the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not access or use the Platform.

2. Information We Collect

2.1 Information You Provide Directly

• RE:Agent account registration: name, email address, phone number, brokerage/office information, and securely hashed password
• RE:Buyer onboarding: name and phone number only — no account or password is required
• Profile information: client preferences, search criteria, communication settings
• Messages: communications sent through the Platform between agents, buyers, and party members
• Property feedback: scorecards, ratings, notes, and photos you submit about properties
• Other information: any information you voluntarily provide when contacting us or using Platform features

2.2 Information Collected Automatically

When you use the Platform, we and our service providers may automatically collect:

• Device information, including device type, operating system, and device identifiers
• Usage data, including features used, screens visited, and actions taken
• Precise geolocation data, if you grant permission through your device settings, to provide map-based property search and driving directions. You may withdraw consent through your device settings, though this may limit certain features.
• Log data, including access times and error logs

2.3 Information from Third Parties

We may receive information from third-party sources, including:

• Multiple Listing Services (MLS) for property listing data, photos, and market information
• Real estate professionals who interact with you through the Platform
• Third-party authentication services if you choose to log in using a third-party account

3. Legal Basis for Processing

We process your personal information based on the following legal bases:

• Performance of contract: when necessary to provide Platform services you have requested
• Legitimate interests: to operate, improve, and secure the Platform
• Legal obligations: where required by applicable law
• Consent: where required by applicable law, such as for marketing communications or precise geolocation

4. How We Use Your Information

4.1 Platform Operations

• Create, maintain, and manage your account
• Facilitate connections between realtors and home buyers
• Enable messaging, property sharing, showing coordination, and other Platform features
• Display property listings, agent profiles, and related information
• Process and display scorecards, ratings, notes, and photos
• Provide AI-powered property photo analysis via third-party AI services
• Provide map-based property search and driving directions

4.2 Communications

• Send service-related notices, updates, and administrative messages
• Notify you of changes to our Terms of Service, Privacy Policy, or Platform features
• Respond to your inquiries and provide customer support
• Send promotional or marketing communications, subject to your opt-in consent where required by law. You may opt out at any time using the unsubscribe mechanism in our emails or by contacting us. We will process opt-out requests within ten (10) business days.

4.3 Safety, Security, and Compliance

• Detect, prevent, and respond to fraud, abuse, and security incidents
• Enforce our Terms of Service
• Comply with applicable laws, regulations, and legal obligations

4.4 Platform Improvement

• Analyze usage patterns to improve Platform features and user experience
• Conduct research and development of new features
• Generate aggregated, de-identified data for internal analytics

5. How We Share Your Information

We do not sell your personal information as defined under the Colorado Privacy Act or the California Consumer Privacy Act. We may share your information in the following circumstances:

5.1 With Real Estate Professionals

When you connect with a real estate professional through RE:Buyer, you consent to us sharing your name, phone number, property search activity, scorecards, notes, photos, and messages with that professional to facilitate the connection. Real estate professionals are independent third parties, not employees or agents of Pocket Software, LLC. We are not responsible for how they use your information once shared.

5.2 With Buyer Party Members

When you join a buyer party, your property feedback (scorecards, notes, photos) and messages are shared with other party members and the associated real estate agent. This sharing is a core feature of the Platform and is necessary to provide the collaborative home search experience.

5.3 With Service Providers

We share information with third-party service providers who perform services on our behalf. These providers are contractually obligated to use your information only as directed by us and to implement appropriate security measures. Our current service providers include:

• Supabase — Database hosting, authentication, and backend infrastructure
• Mapbox — Map display, geocoding, and driving directions
• Google (Gemini) — AI-powered property photo analysis
• Firebase (Google) — Push notifications
• PostHog — Product analytics
• Vercel — Website hosting
• Render — Backend API hosting

5.4 With MLS Providers

The Platform integrates with Multiple Listing Services (MLS) to provide property listing data. Information related to your property searches may be exchanged with MLS providers pursuant to their applicable licensing terms and rules. MLS providers have their own data use policies that we do not control.

5.5 For Legal Reasons

We may disclose your information if we believe in good faith that disclosure is necessary to comply with applicable law, enforce our Terms of Service, detect or prevent fraud, or protect the rights, property, or safety of Pocket Software, our users, or the public.

5.6 Business Transfers

If Pocket Software, LLC is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will provide at least thirty (30) days' notice before your personal information becomes subject to a different privacy policy, except where prohibited by law. During this notice period, you may request deletion of your account and personal information.

6. Cookies and Tracking Technologies

Our web applications use local storage for app functionality (such as session management and user preferences). We do not use third-party advertising cookies or tracking pixels for targeted advertising.

We use PostHog for product analytics to understand how users interact with the Platform. You may control tracking through your browser settings. We honor browser-based Global Privacy Control (GPC) signals as an opt-out of the sale or sharing of personal information to the extent required by applicable law.

Our mobile applications do not use cookies. Device identifiers may be collected for push notification delivery and analytics as described in Section 2.2.

7. Data Retention

We retain your personal information for as long as necessary to provide Platform services and comply with our legal obligations. Specific retention periods include:

• Account information: retained for the duration of your active account plus three (3) years after account closure
• Messages and communications: retained for seven (7) years for legal compliance purposes
• Property activity (scorecards, notes, photos): retained for the duration of your active account. Property-specific data may be deleted sooner if a listing is removed from the MLS
• Activity logs and showing history: retained for seven (7) years
• De-identified or aggregated data: may be retained indefinitely

Upon account deletion, you may retrieve your personal data within thirty (30) days by contacting us. After this period, we will delete or anonymize your personal information within one hundred eighty (180) days, except where retention is required by law or for legitimate business purposes such as fraud prevention or dispute resolution.

8. Data Security

We implement appropriate administrative, technical, and physical safeguards to protect your information against unauthorized access, disclosure, alteration, or destruction. These measures include encryption of data in transit (TLS/SSL), access controls, and secure hosting environments. However, no method of electronic storage or transmission is 100% secure, and we cannot guarantee absolute security.

You are responsible for maintaining the confidentiality of your account credentials and for any activities that occur under your account. Please notify us immediately at support@pocketsoft.co if you suspect unauthorized access.

9. Your Privacy Rights

9.1 Colorado Privacy Act (CPA)

If you are a Colorado resident, you have the following rights with respect to your personal data:

• Right to Access: request access to the personal data we hold about you
• Right to Correction: request correction of inaccurate personal data
• Right to Deletion: request deletion of your personal data, subject to certain exceptions
• Right to Data Portability: request a copy of your personal data in a portable format
• Right to Opt Out: opt out of the processing of your personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects. Pocket Software, LLC does not sell personal data or engage in such profiling.

We will respond to verified requests within forty-five (45) days, with a possible extension of an additional forty-five (45) days where necessary. If we deny your request, you have the right to appeal our decision by contacting us.

9.2 California Residents — CCPA/CPRA

If you are a California resident, you have the following additional rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA):

• Right to Know: request disclosure of the categories and specific pieces of personal information we have collected about you
• Right to Delete: request deletion of personal information we have collected
• Right to Correct: request correction of inaccurate personal information
• Right to Opt Out of Sale/Sharing: opt out of the sale or sharing of your personal information. Pocket Software, LLC does not sell personal information.
• Right to Non-Discrimination: you will not receive discriminatory treatment for exercising your privacy rights

We will acknowledge receipt of your request within ten (10) business days and respond within forty-five (45) days, with a possible extension of up to an additional forty-five (45) days where reasonably necessary.

9.3 All Users

Regardless of your location, you may:

• Update or correct your account information through your account settings
• Request deletion of your account by contacting us
• Opt out of marketing communications by clicking the unsubscribe link in any marketing email or contacting us directly

To exercise any privacy right, contact us at privacy@pocketsoft.co with "Privacy Rights Request" in the subject line.

10. Children's Privacy

The Platform is not directed to individuals under the age of 18, and we do not knowingly collect personal information from minors. You must be at least 18 years old to use the Platform. If we become aware that we have collected personal information from a person under 18, we will take steps to delete that information promptly. If you believe we have inadvertently collected information from a minor, please contact us immediately.

11. Third-Party Links and Services

The Platform may contain links to third-party websites and services, including MLS systems, mortgage resources, and other real estate tools. This Privacy Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third party you interact with through the Platform.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or Platform features. If we make material changes, we will notify you through the Platform, by email, or by posting a notice on our website at least seven (7) days before the changes take effect. Your continued use of the Platform after such notice constitutes acceptance of the updated Privacy Policy.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Pocket Software, LLC
Email: privacy@pocketsoft.co
General support: support@pocketsoft.co