Clozara Privacy Policy

1.1 Who this Policy covers. This Policy applies to two groups: (a) Agents. Real estate professionals and their organizations who create an account and use the Service. (b) Contacts. Individuals whose information an Agent uploads or enters into the Service, such as past clients, leads, and sphere contacts.

1.2 Our role. For personal information about Agents and for operating the Service, we act as a business or controller. For Contact Data that an Agent uploads, the Agent determines the purposes and means of processing, and we process that information as a service provider or processor on the Agent's behalf and on the Agent's instructions. If you are a Contact and wish to exercise rights over your information, the most direct route is often the Agent who holds it. You may also contact us and we will assist or refer your request to the responsible Agent.

We collect the following categories of personal information. Not every category applies to every person.

2.1 Identifiers and account information. Name, email address, telephone number, agent type, time zone, delivery preferences, and login credentials managed through our authentication provider.

2.2 Contact Data provided by Agents. Contact records that Agents upload or enter, which may include a Contact's name, email address, telephone number, contact type, notes, life events, timelines, price ranges, an equity indicator, and last contact dates.

2.3 Commercial and transaction information. Subscription tier, billing status, purchase and renewal history, and referral activity. Payment card details are collected and processed by our payment processor, not stored by us.

2.4 Usage and activity information. Records generated as you use the Service, such as briefings, logged call outcomes, ratings, win submissions, and referral records.

2.5 Device and technical information. Information automatically collected when you use the Service, such as IP address, browser type, device identifiers, and log data, to the extent collected by us or our providers.

2.6 Communications. Records of your communications with us, including support requests.

We do not intentionally collect Social Security numbers, government identifiers, precise geolocation, biometric information, or other sensitive categories of personal information, and you should not upload such information to the Service.

We collect personal information (a) directly from you, such as when you register, subscribe, or contact us; (b) from Agents, in the case of Contact Data; (c) automatically through your use of the Service; and (d) from our service providers, such as our payment processor for billing status.

We use personal information for the following business and commercial purposes: (a) to provide, operate, maintain, and secure the Service, including creating and managing your Account; (b) to generate Outputs, including daily briefings, reactivation reports, opportunity scores, and suggested outreach; (c) to deliver briefings and notifications by email, and by SMS where an Agent enables it; (d) to process payments, manage Subscriptions, prevent billing errors, and administer referral credits; (e) to provide customer support and respond to requests; (f) to monitor, detect, prevent, and address fraud, abuse, security incidents, and violations of our Terms; (g) to analyze usage and improve and develop the Service; and (h) to comply with legal obligations and enforce our agreements.

To generate Outputs, we transmit relevant details from Your Data to our artificial intelligence provider, which processes that data to return the requested reason, recommended action, suggested outreach, and related content. We instruct our provider to process this data solely to provide the service to us. The Service does not use these Outputs to make decisions that produce legal or similarly significant effects concerning a Contact without human involvement. Agents review Outputs and decide whether to act on them.

6.1 No sale of personal information. We do not sell personal information, and we do not share personal information for cross context behavioral advertising, as those terms are defined under applicable law.

6.2 Service providers. We disclose personal information to service providers that perform functions on our behalf, under contracts that limit their use of the information to providing services to us. These functions include: (a) cloud hosting, database, and authentication; (b) artificial intelligence processing; (c) payment processing; (d) email delivery; and (e) SMS delivery, where enabled.

6.3 For Agents, on their behalf. We disclose Contact Data and Outputs to the Agent who uploaded or generated them, because we process that information on the Agent's behalf.

6.4 Legal and safety. We may disclose personal information to comply with law, regulation, legal process, or governmental request, to enforce our Terms, and to protect the rights, property, and safety of Clozara, our users, and the public.

6.5 Business transfers. If we are involved in a merger, acquisition, financing, reorganization, or sale of assets, personal information may be transferred as part of that transaction, subject to this Policy.

Depending on where you live, you may have some or all of the following rights, subject to legal limits and exceptions: (a) the right to know and access the personal information we hold about you and how we use and disclose it; (b) the right to correct inaccurate personal information; (c) the right to request deletion of your personal information; (d) the right to obtain a portable copy of your personal information; (e) the right to opt out of the sale or sharing of personal information, and to limit the use of sensitive personal information, although we do not sell or share personal information or use sensitive personal information for such purposes; and (f) the right not to receive discriminatory treatment for exercising your rights.

7.1 How to exercise your rights. To exercise a right, contact us at jason@cosbyaisolutions.com. We will acknowledge and respond within the timeframes required by applicable law.

7.2 Verification. To protect your information, we will take steps to verify your identity before fulfilling a request, which may include confirming information associated with your Account or request.

7.3 Authorized agents. You may use an authorized agent to submit a request on your behalf where permitted by law, subject to proof of authorization and verification of your identity.

7.4 Appeals. Where required by applicable law, if we decline your request, you may appeal by replying to our response or contacting jason@cosbyaisolutions.com, and we will respond as required.

7.5 Global Privacy Control. Where required, we honor recognized browser based opt out preference signals such as the Global Privacy Control to the extent applicable to our processing.

7.6 If you are a Contact. If your information was uploaded by an Agent, we process it on that Agent's behalf. We will, as required by law, forward your request to the Agent or assist the Agent in responding. You may also contact the Agent directly.

We may send you Service related transactional messages, such as billing and security notices, which are necessary to operate your Account and which you cannot opt out of while your Account is active. If we send marketing emails, you may opt out at any time using the unsubscribe link or by contacting us. If you enable SMS features, you may opt out of Service text messages by replying STOP. Message and data rates may apply.

The Service may use cookies and similar technologies to keep you signed in, remember preferences, secure the Service, and understand usage. You can control cookies through your browser settings, although disabling some cookies may affect functionality.

We retain personal information for as long as needed to provide the Service, comply with our legal obligations, resolve disputes, and enforce our agreements. When you request deletion of your Account, we schedule deletion of your Account and associated data, including Contacts, briefings, briefing items, call logs, and win submissions, and remove it within the stated window, currently ninety days after the request, except where we are required or permitted by law to retain certain records. Backups are purged on their normal cycle.

We maintain administrative, technical, and organizational safeguards designed to protect personal information, including access controls, row level security that restricts each Agent to their own records, and encryption of data in transit. No system is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your credentials confidential and for the security of data you export from the Service. If we become aware of a security incident affecting your personal information, we will notify you and applicable authorities as required by law.

The Service is intended for real estate professionals and is not directed to children under 18, and we do not knowingly collect personal information from children. If you believe a child has provided personal information to us, contact us and we will take appropriate steps to delete it.

The Service may contain links to, or integrate with, third party websites and services that we do not control. This Policy does not apply to those third parties, and we encourage you to review their privacy policies.

We operate the Service in the United States, and personal information is processed in the United States. If you access the Service from outside the United States, you understand that your information will be transferred to and processed in the United States, where data protection laws may differ from those in your jurisdiction.

We may update this Policy from time to time. If we make material changes, we will provide notice through the Service or by email and update the effective date above. Your continued use of the Service after the changes take effect constitutes acceptance of the updated Policy.

If you have questions or requests regarding this Policy or your personal information, contact Cosby AI Solutions LLC doing business as Clozara at jason@cosbyaisolutions.com.