Privacy Policy

1. Summary

This Privacy Policy explains how The Real Brokerage Inc. collects, uses, and shares personal data in connection with our digital services and AI tools such as Leo. It applies to consumers, agents, and visitors in the U.S. and Canada. Additional state and provincial rights appear in the “Privacy Rights” section below.

2. Introduction

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. References to “Agents” in this Policy mean licensed real-estate professionals acting as independent contractors of Real’s brokerage entities, not employees or affiliates.

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 including artificial intelligence (“AI”) powered tools such as Leo, 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; and

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 Digital 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.

3. Age Requirement

Our Services are not intended for children under 18 years of age. No one under age 18 may provide any information to or through the Digital Services. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on or in our Digital Services or on or through any of their features, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. AI Tools are not directed to individuals under 18. If we learn that an AI interaction log includes information from a minor, we will promptly delete it. If you believe we might have any information from a child under 18, please email us at [email protected] or call us at 646-859-2368 (United States) or 782-820-4098 (Canada).

4. Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Digital Services (“Personal Data”) to operate, improve, and provide our products and services.

A. Information You Provide to Us

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.

The Personal Data we collect includes:

Information that you provide by filling in forms on our Digital Services, including information supplied when registering an account, using or purchasing products or services, or requesting further assistance. We may also ask you for information when you report a problem with our Digital Services;

Records and copies of your correspondence with us, such as your email address, email content, phone number, and recordings or transcriptions of calls.

Your responses to surveys we ask you to complete for research, development, or marketing purposes.

Details of transactions (including electronic-signature transactions) you carry out through our Digital Services and the fulfillment of those orders or services. You may be required to provide financial information before placing an order or requesting certain services.

You also may provide information to be published or displayed (“User Contributions”) on public areas of the Digital Services or transmitted to other users or third parties. User Contributions are posted at your own risk. Although we limit access to certain pages, no security measures are perfect, and we cannot control the actions of other users who may view or share your content.

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.

We collect this information:

Directly from you when you provide it or communicate with us;

Automatically as you navigate or use our Digital Services (see Section C below); and

From third parties such as data aggregators and business partners.

B. Information We Collect from Independent Contractor Agents

We may receive your contact information (for example, name, phone number, or email address) from independent contractor real-estate professionals operating under the Real brand (“Agents”) when you provide that information to them in connection with a real-estate inquiry or transaction. This may include contact information uploaded by Agents for marketing or outreach purposes using Real’s systems.

Real processes this information to facilitate your requested communications or services through our platforms. Agents act as independent contractors, not employees or affiliates of Real.

If an Agent participates in AI features, Real may collect related usage data as a service provider for the Agent, subject to this Policy.

C. Information We Collect Automatically

When you use our Digital Services, we automatically collect information about your device, browsing activity, and usage patterns through cookies, analytics tools, and similar technologies. This may include information generated through your interactions with AI Tools, including conversation logs and metadata. AI interaction logs may be retained as necessary to provide services, comply with legal obligations, or enforce our rights, and are then securely deleted or anonymized.

As you navigate through and interact with our Digital Services, we may use automatic data-collection technologies to gather information about your equipment, browsing actions, and patterns, such as:

Usage Details. Traffic data, location, logs, referring/exit pages, date and time of your visit or use, error information, clickstream data, and the resources you access and use.

Device Information. Details about your computer, mobile device, and Internet connection, including IP address, operating system, browser type, and app version.

Location Data. Information about your location collected through geolocation technology.

This automatically collected information helps us improve our Digital Services and deliver a more personalized experience by enabling us to:

Estimate audience size and usage patterns;

Improve our product and service offerings;

Store information about your preferences to customize the Digital Services; and

Recognize you when you return to the Digital Services.

D. Technologies We Use.

Cookies (or browser cookies). We and our service providers use cookies, web beacons, and similar technologies to receive and store certain information whenever you interact with our Digital Services through your computer or mobile device. You may refuse cookies through your browser or device settings, but some features may not function properly if you do so. These technologies may include cookies and pixels used for analytics, functionality, and advertising, including cookies used to deliver interest-based and retargeted advertisements on third-party websites and platforms

Pixels and Web Beacons. Pages on our Digital Services or our emails may contain small electronic files (clear GIFs, pixel tags, or single-pixel GIFs) that allow us to, for example, count users who have visited a page or opened an email and verify system and server integrity. These technologies may also be used by us and our advertising partners to understand the effectiveness of advertising campaigns and to deliver advertisements to users who have previously visited our Digital Services.

Google Analytics. We use Google Analytics, a web-analytics service provided by Google Inc., to help us analyze site usage and improve performance. You can learn more about how Google uses data at www.google.com/policies/privacy/partners/

Intercom. We use Intercom Inc. analytics and messaging services to analyze usage and, where applicable, provide in-product communications. For more information, visit https://www.intercom.com/legal/privacy

Analytics and telemetry are used within our authenticated, internal platforms, including reZEN, to operate, secure, maintain, and improve those platforms. This data may include usage data, event data, performance metrics, and related identifiers collected through tools such as Mixpanel. Because these platforms are internal business tools and not public-facing websites, such analytics are required for use of the platform and are not subject to cookie preference settings or opt-out controls applicable to public-facing sites.

5. How We Use Your Information

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

To provide and operate our Digital Services (including our Website and App) and their functionality, content, and services;

To provide our products and services, 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 you purchase or use;

To personalize your experience with our Digital Services and to deliver content and product offerings relevant to your interests;

To market our financial products and services (such as corporate charge cards and debit cards) and to determine your eligibility for those products;

To provide personalized and interest-based advertising including displaying advertisements to you on third-party websites and platforms based on your interactions with our Digital Services;

To provide notices about your account and respond to your inquiries or requests;

To enable lawful communications between you and independent contractor agents using Real’s systems, in accordance with applicable consent and privacy laws;

To carry out our obligations and enforce our rights under contracts between you and us (including for billing, collection, or enforcement of our financial partners’ rights under cardholder agreements);

To notify you about changes to our Digital Services or products;

To develop and improve our products, services, and AI Tools (including Leo), including by testing and monitoring performance and analyzing business operations;

To transmit communications initiated by Agents using AI-assisted tools, in accordance with applicable consent laws

To fulfill any other purpose for which you provide the information;

In any other way we describe when you provide the information;

For any other purpose with your consent; and

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.

6.  Disclosure of Your Information

A. Disclosure to Affiliates, Service Providers and Vendors

We disclose information to our affiliates, contractors, service providers, and other third parties we use to support our business. These third parties are bound by contractual obligations to keep Personal Data confidential and to use it only for the purposes for which we disclose it.  In addition, we may share address-only property transaction information, including addresses derived from our brokerage systems such as reZEN, with our affiliated entities (including One Real Mortgage and One Real Title) for business and marketing purposes. No client-identifying information is included in such data sharing.

B. Disclosure for Legal and Compliance Purposes

We may disclose Personal Data to:

Comply with any court order, law, or legal process, including to respond to lawful government or regulatory requests;

Enforce or apply our Terms of Use, Agent Terms of Service, or other agreements; and

Protect the rights, property, or safety of Real, our customers, agents, or others.

C. Service Provider Role for Agent Communications

When consumers interact with independent contractor agents through Real’s systems, Real acts as a technology service provider on behalf of the Agent.
Real may process and transmit consumer contact information (such as name, phone number, or email address) to facilitate these communications, but Real does not initiate outreach or determine message content. This includes initial outbound communications initiated by the Agent. Agents are solely responsible for compliance with the Telephone Consumer Protection Act (TCPA), the CAN-SPAM Act, and any other applicable communications laws.

D. Corporate Transactions

We may disclose Personal Data in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of Real assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Real about our Digital Services users is among the assets transferred.

E. Aggregate or De-Identified Information

We may disclose aggregated or de-identified information that does not identify any individual for research, analytics, or marketing purposes.

F. Special Disclosure Relating to Agents and Financial Products

We may 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. If we offer Financial Products in your jurisdiction, 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.

G. Marketing to Real Estate Agents Affiliated with Real by Real Affiliates

We may share the personal information of real estate agents (including brokers) affiliated with our Real brokerage entities with Real affiliate businesses that offer mortgage broker (“One Real Mortgage”), title insurance (“One Real Title”) and other products and services. The shared information may include personal contact information, commission information and other information that was provided to Real brokerage entities, including information provided through the reZEN application. The Real affiliates, including One Real Mortgage and One Real Title and its affiliates, may use the information for their business and commercial purposes including to send marketing communications about their products and services and to conduct digital and targeted advertising, including through audience-matching on third-party platforms. Real estate agents may elect to not have their information shared with Real affiliates at any time by contacting us at [email protected] or Real Broker, LLC, c/o Real Support, 39889 Balentine Dr., Suite 200, Newark, CA 94560, and stating, in the e-mail or letter, “I hereby elect to not have my information shared with Real’s affiliates, and elect to not have Real’s affiliates use my information to market to me”.

7. Artificial Intelligence Disclosures

Certain features of our Digital Services use artificial intelligence (“AI”) and machine-learning technologies, including Leo and related tools. This section provides additional information about how AI functionality interacts with Personal Data.

Use of AI Tools. In connection with your use of our Services, the Company may make available artificial intelligence (AI) features, including “Leo,” the Company’s AI-powered assistant (“AI Tools”). These tools are intended to enhance your experience but are not a substitute for professional judgment or advice. Personal information processed by AI Tools includes information you provide to the AI Tool and related interaction data (e.g., logs/metadata) necessary to operate the feature, as described in this Policy.

Safeguards. AI interactions are subject to access controls and technical safeguards. Real does not publicly disclose or sell AI interaction data and limits employee access to such data to authorized personnel with a need to know.

Service Provider Role. When AI Tools are used by Agents in their communications with consumers, Real acts as a technology service provider to those Agents and processes related information on their behalf in accordance with this Policy

Retention. We retain AI interaction logs only as long as necessary to provide services, meet compliance obligations, or enforce our rights, and then securely delete or de-identify them.

Certain features of Real’s Digital Services, including the HeyLeo platform and the AiRM (AI-powered Relationship Manager) pipeline, involve automated processing of personal information beyond general conversational AI interactions. This section describes those activities.

Automated Profiling of Buyers and Leads. When an Agent uses Real’s systems to upload contact or lead data for outreach purposes, AiRM may process that data to generate structured buyer profiles used to support property recommendations and outreach communications. This processing may include:

Reading and interpreting notes, tags, and interaction history from CRM or other data exports

Extracting housing preferences, location priorities, and property characteristics of interest

Inferring housing price-range signals and purchase readiness indicators based on available information

Inferring household-related signals such as family composition or lifestyle preferences where reflected in uploaded data

Classifying buyer intent (for example, actively looking, passively looking, or not currently looking)

Classifying communication receptiveness in order to tailor outreach approaches

These automated processes are used to personalize communications and property recommendations. They are not used to make legally significant decisions about individuals or to determine eligibility for financial services, housing, or credit.

Cross-Channel Profile Unification. HeyLeo integrates communications and engagement signals across multiple channels, including SMS, email, and web chat. Interactions across these channels may be associated with a single buyer profile so that communications and recommendations can reflect prior interactions. For example, signals from a text conversation, an email response, or browsing activity on a property page may inform the same profile used to generate future communications.

AI-Generated Communications. Based on buyer profiles and available property listings, AiRM may generate personalized email or SMS communications on behalf of an Agent. These communications are sent from the Agent’s dedicated HeyLeo email address or phone number. Buyers receiving such communications may be interacting with content generated with the assistance of artificial intelligence systems. Agents may review or intervene in communications where platform functionality allows.

Third-Party Data Sources. In connection with property search and recommendations, Real’s systems may draw on information from third-party data sources, including:

Multiple Listing Service (MLS) listing data

Local Logic neighborhood and school information

property image analysis and search technologies

These data sources may inform property recommendations and outreach content generated through the HeyLeo platform.

Agent Responsibility. Agents are solely responsible for ensuring that any personal information uploaded to Real’s systems for use with AiRM has been collected and used in compliance with applicable law, including obtaining any required consent for outreach communications. Real processes this data as a technology service provider supporting the Agent’s use of the platform.

Your Rights. If you are a buyer or lead whose information has been processed as described in this section, you may have rights under applicable state or Canadian privacy laws to request access to, correction of, or deletion of your personal information. Note: Canadian privacy law provisions, including those arising under PIPEDA and applicable provincial legislation, should be reviewed by Canadian counsel before this language is finalized for Canadian-facing disclosures. To exercise these rights, contact: [email protected].

8. Additional Terms Applicable to AI Tools

AI Identification. Interactions with AI Tools are automated and not conducted by a human.

Informational Only. AI outputs may be inaccurate, incomplete, or outdated. They are provided for informational purposes only and do not constitute legal, financial, compliance, or professional advice.

Verification Obligation. You are solely responsible for verifying the accuracy and appropriateness of AI outputs before relying on them.

Sensitive Data. You may not input Social Security numbers, Social Insurance numbers, payment card details, banking credentials, biometric identifiers, health data, or other sensitive information. Such data is not required for your use of AI features or AI Tools.

Fair Housing Disclaimer. AI outputs are not reviewed for compliance with the Fair Housing Act, RESPA, or state housing laws. Consumers should not rely on AI outputs as statements of eligibility, preference, or availability of housing.

Training Data. Leo is built on Google Gemini (Flash and Pro) model and further trained with Real’s internal documentation, document libraries, and publicly available state real estate rules. Anonymized interaction data may be used to improve performance. Leo also uses a mix of proprietary and publicly available datasets, including environmental, infrastructure, and demographic data from U.S. and Canadian open-data portals. These sources are selected under open licenses and used in accordance with their terms 

Large-User Compliance. If Real’s AI services exceed one million monthly users, we will comply with SB 942 (transparency, risk assessment, reporting). We provide summaries of training data sources under AB 2013.

Retention and Audit. AI interaction logs may be retained as necessary to provide services, comply with obligations, or enforce rights, and will then be deleted or anonymized. Logs may be disclosed as required by law or Company policy.

Third-Party Providers.  To enable AI features, limited data may be processed by AI infrastructure providers including Google (for Gemini model services), Groq (for inference services), and OpenRouter (a routing intermediary through which requests may be directed to underlying model providers such as Anthropic, OpenAI, and others). Data processed through these providers is subject to contractual terms governing its use and protection. The specific providers and models in use may change over time as the platform evolves. Your use may also be subject to those providers’ policies.

Ownership and Licensing. You retain ownership of your inputs but grant the Company a license to use inputs and outputs to operate and improve AI Tools. AI outputs are the property of the Company and may not be reproduced or exploited except for your personal use of the Services.

Transparency & Labeling. AI-generated content may include visible or embedded labels identifying its AI origin.

Consumer Choice. You may opt out of AI interactions and request a human agent at any time by texting “HUMAN” in the Leo text chat.

Accessibility. Reasonable accommodations for alternative accessible formats will be provided as required by law by contacting [email protected].

Reporting. If you believe AI outputs contain harmful, discriminatory, or unlawful content, you may report this to [email protected].

Evolving Compliance. We may update these AI disclosures as laws and regulations evolve. Continued use of AI Tools constitutes acceptance of such updates.

9. Choices About How We Use and Disclose Your Information

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:

Agent Communications. If you no longer wish to receive text messages or emails from an independent contractor agent, reply STOP to SMS messages or use the unsubscribe link in marketing emails. Opt-out requests apply to future communications sent through Real’s systems on behalf of that Agent.

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. You may also be presented with a cookie or preference banner that allows you to accept or decline certain categories of cookies, including advertising cookies, where required by law. 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 [email protected].

Interest-Based Targeted Advertising.

We may use your Personal Data to provide interest-based advertisements from us and that are customized to your 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. These advertising partners may include social media platforms, search engines, and other advertising technology providers such as Google, Facebook and Instagram which use cookies to serve ads based on your prior visits to our Digital Services. These advertising platforms use this information to provide you with interest-based advertisements that are customized to your 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, including retargeted advertisements based on prior visits or interactions, 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).

10. Your Rights and Choices Regarding Your Information and Accessing and Correcting Your Information

You may contact us to access, delete, or change your Personal Data. You may also be able to review, delete, and change your Personal Data by logging into the Digital Service and visiting your Account Preferences page. However, please note that we may retain records of your information for legal, compliance and audit purposes, even after your information has been deleted from or changed in your account.

You can Contact Us to access and/or find out what information we have about you, and to correct that information. You can also review and change your Personal Data by logging into our Digital Services and visiting either the Settings or Account Preferences sections of our Digital Services. You may also notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible or to delete your account. We may not be able to delete some of your Personal Data except by also deleting your account with us. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

Cookies. You can change the cookie settings that will be placed when you use our Digital Services by changing the settings on your Internet browser. You can also block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Please note that internet browsers allow you to change your cookie settings. These settings are usually found in the ‘options’ or ‘preferences’ menu of your internet browser. However, if you use your browser settings to block all cookies (including strictly necessary cookies), you may not be able to access or use all or areas and aspects of our Digital Services.

Personalized and interest-based advertising. You can generally opt out of receiving personalized and interest-based advertisements from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt out pages on the NAI website and DAA website. 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 also opt out of receiving targeted ads from members of the NAI on its website. You can learn more about interest-based advertisements and your opt out rights and options on the NAI website and DAA website.

Messages. If you do not wish to have your email address used by Company to send you advertising messages and content, you can opt out at any time by clicking the unsubscribe link at the bottom of any marketing emails you receive from us. You may have other options with respect to marketing and communication preferences through our Digital Services.

AI. In some jurisdictions, you may have additional rights related to AI interactions, such as the right to opt out of automated decision-making, to request human review, or to restrict certain types of profiling. We will honor these rights as required by applicable law.

11. Do Not Track Signals

We currently do not respond to “Do Not Track” signals transmitted by web browsers. However, we do recognize and honor Global Privacy Control (GPC) signals as required by applicable state law. When we detect a GPC signal, we will treat it as a valid opt-out request for the sale or sharing of personal information associated with that browser. Our Digital Services may use cookies and similar technologies, including advertising and retargeting cookies, that collect information about your interactions with our Digital Services and third-party websites.

12. Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Digital Services confidential.

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. We use encryption technology for information sent and received by us.

The safety and security of your information also depend on you. Where you have chosen a password for the use of our Digital Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to, on or through our Digital Services. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website, in your operating system, or in the App.

13. Privacy Rights in California, Certain Other US States and Canada

In addition to the disclosures and rights set forth elsewhere in this Policy, you and other users may have certain rights based on applicable U.S. state and Canadian law, for example, the California Consumer Privacy Act, as updated by the California Privacy Rights Act (CCPA) or Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA). 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 U.S. state and Canadian law applies to Real and your use of our Digital Services. Where AI-specific rights exist under state law (e.g., AB 2013, SB 942), Real will provide required disclosures and compliance measures. Please contact us if you have any questions regarding your rights under applicable state or Canadian law.

A. 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 and PIPEDA) about you when you visit or 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).

B. 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.

C. 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”).

D. 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”).

E. 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.

F. 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.

G. 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.

H. 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 using 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. This opt-out applies to cookie-based advertising and retargeting technologies used on our Digital Services. This opt-out applies to cookie-based advertising and retargeting technologies used on our Digital Services. To opt out of having your information shared with Real affiliates for targeted advertising purposes, including audience-matching on third-party platforms, see Section 6.G above.

I. 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.

J. 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 (305) 306-9553 (United States) or (604) 200-7046 (Canada).

Emailing us at [email protected].  

Only you, or your legal representative authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information, including requests to access your Personal Information. 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.

K. Non-Discrimination

We will not discriminate against you for exercising any of your rights under applicable U.S. state or Canadian 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.

14. Job Applicants

If you apply for employment with Real, we collect and process the information you provide in connection with your application.

This may include your name, contact information, resume or curriculum vitae, employment and education history, qualifications, and any other information you choose to submit.

We use applicant data to:

Evaluate and manage applications and recruiting processes;

Conduct background checks or other due diligence as permitted by law;

Communicate with you about potential employment; and

Comply with applicable legal and regulatory obligations.

We may share applicant data with affiliates, service providers, or partners assisting in recruitment, and with authorities where required by law.
Applicant information is retained only as long as necessary for hiring and legal compliance purposes.

Text Messaging for Recruiting. If you provide your mobile number as part of your application, we or our recruiting service providers may send you SMS or text messages related to your application or scheduling interviews. By providing your number, you consent to receive such text messages. Message frequency will vary based on the hiring process. You can opt out at any time by replying STOP to any message. Your consent to receive texts is not a condition of applying for or obtaining employment. Message and data rates may apply.

15. International Users (Outside of the United States and Canada)

Our Website is intended for use by residents in the United States and Canada. Our Website is not intended for use by and is not directed to residents of the European Union. All data is stored and processed in the United States. By using and accessing our site, users who reside or are located in countries outside of the United States (including users in Canada) agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

16. Changes to This Privacy Policy

We will post any changes to our Privacy Policy on our Website. If we make material changes to our Privacy Policy, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website’s home page or the App’s home screen. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the email address specified in your account and/or through a notice on the Website’s home page or the App’s home screen. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically accessing the App or visiting our Website and reviewing this Privacy Policy to check for any changes.

17. Contact Information

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below or through the “Contact Us” page on or in our Digital Services.

How to Contact Us:

Telephone: (305) 306-9553 (United States) or (604) 200-7046 (Canada).

Email: [email protected]

© 2026 The Real Brokerage Inc. All rights reserved. Last Updated March 2026.

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Contact

[email protected]

972-658-7462