CLA PROPERTY SOLUTIONS

PRIVACY POLICY

Last updated January 2, 2026

IMPORTANT NOTICE REGARDING TEXT MESSAGING DATA

("we," "us," or "our") DOES NOT share customer opt-in information, including phone

numbers and consent records, with any affiliates or third parties for marketing,

promotional, or any other purposes unrelated to providing our direct services. All text

messaging originator opt-in data is kept strictly confidential.

This privacy notice for ("we," "us," or "our"), describes how and why we might

collect, store, use, and/or share ("process") your information when you use our

services ("Services"), such as when you:

Visit our website at , or any website of ours that links to this privacy policy

Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy policy will help you understand your

privacy rights and choices. If you do not agree with our policies and practices, please

do not use our Services. If you still have any questions or concerns, please contact

us at CLA PROPERTY SOLUTIONS

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more

details about any of these topics by clicking the link following each key point or by

using our table of contents below to find the section you are looking for.

Do we process any sensitive personal information?

We do not process sensitive personal information.

Do we receive any information from third parties?

We do not receive any information from third parties.

How do we process your information?

We process your information to provide, improve, and administer our Services, communicate

with you, for security and fraud prevention, and to comply with law. We may also process

your information for other purposes with your consent. We process your information only

when we have a valid legal reason to do so. Learn more about how we process your

information.

We do not share or disclose your personal information except in very specific, rare

circumstances, and always with your consent. For instance, if we ever need to share

data due to a business transfer, merger, or acquisition, we will notify you and ensure

your privacy is protected.

No mobile information will be shared with third parties/affiliates for

marketing/promotional purposes. Information sharing to subcontractors in support

services, such as customer service is permitted. All other use case categories

exclude text messaging originator opt-in data and consent; this information will not

be shared with any third parties.

In what situations and with whom do we share personal information?

We value your privacy and never share your personal information with third parties. Your

information remains confidential and is only used for the purpose of providing our services to

you.

How do we keep your information safe?

We have organizational and technical processes and procedures in place to protect your

personal information. However, no electronic transmission over the internet or information

storage technology can be guaranteed to be 100% secure, so we cannot promise or

guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to

defeat our security and improperly collect, access, steal, or modify your information. Learn

more about how we keep your information safe your personal information remains private

and secure with us at all times.

We do not sell, distribute, or disclose your personal information to mailing lists or

other third parties without your explicit consent. If requested, we can add your

contact to business-related mailing lists, but you may opt-out at any time. Your

personal information is always protected, and we will take appropriate steps to ensure

its security.

We will not, in any circumstances, share your personal information with other

individuals or organizations without your permission, including public organizations,

corporations or individuals, except when applicable by law. We do not sell,

communicate or divulge your information to any mailing lists. We can offer to add

your address to an Info Entrepreneurs or Canada Business Network mailing list or list

server if you request it. In this last case, you may at any time ask us to remove your

name from such lists.The only exception is if the law or a court order compels us to.

We will share your information with government agencies if they need or request it.

What are your rights?

Depending on where you are located geographically, the applicable privacy law may mean

you have certain rights regarding your personal information. Learn more about your privacy

rights.

How do you exercise your rights?

The easiest way to exercise your rights is by submitting a data subject access request, or by

contacting us. We will consider and act upon any request in accordance with applicable data

protection laws.

Want to learn more about what we do with any information we collect?

Review the privacy notice in full.

1. Information We Collect

We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an

interest in obtaining information about us or our products and Services, when you participate

in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on

the context of your interactions with us and the Services, the choices you make, and the

products and features you use. The personal information we collect may include the

following:

Personal Information:

Name, email address, phone number, physical address

Payment information when you make a purchase or request a quote

Opt-in records and timestamps for all communication channels (SMS, email, etc.)

Non-Personal Information:

IP address, browser type, device information

Website usage patterns and preferences

Cookies and similar technologies

Customer Communication:

Records of inquiries and service requests

Appointment details and preferences

Service history and feedback

We process your personal information to deliver our real estate services, including:

Providing and improving our services

Processing transactions and payments

Communicating with you about your inquiries, appointments, and promotions

Enhancing website functionality and user experience

Ensuring security and fraud preventions

Maintaining records of your communication preferences and consent

Property Inquiries & Support:

To respond to your inquiries, schedule viewings, and assist with any real estate-related

questions.

Transactions & Contracts:

To help manage the purchase, rental, or sale of properties, including processing contracts,

payments, and documentation.

Marketing Communications:

To send you updates about new properties, promotional offers, or real estate market news.

You can opt out of marketing communications at any time.

Targeted Advertising:

To show you personalized property recommendations and advertisements based on your

preferences and interests.

Legal Compliance:

To ensure compliance with real estate laws and regulations, and to respond to legal

requests.

2. How We Use Your Information

We process your information to provide, improve, and administer our services, communicate

with you, for security and fraud prevention, and to comply with law. We may also process

your information for other purposes with your consent.

3. SMS Messaging & Compliance

Text Message Platform Terms & Conditions

By opting into our SMS messaging services, you agree to receive text messages related to

our services, including appointment reminders, customer support, and important updates.

Opt-In Consent:

You will only receive messages if you have explicitly opted in.

We maintain timestamped records of all opt-in actions.

We comply with the Telephone Consumer Act (TCPA) and all applicable laws.

Opt-Out Instructions:

You can cancel SMS notifications at any time by replying "STOP"

You will receive a final confirmation message, and no further messages will be sent unless

you re-opt in

All opt-out requests are processed within 24 hours

Message Frequency & Content:

Message frequency varies based on your interactions with our business

Messages will be directly related to the services you have requested

We do not send promotional content without specific consent

Help & Support:

Reply "HELP" for assistance or contact us at CLA PROPERTY SOLUTIONS

Customer support is available during regular business hours

Carrier Information:

Standard message and data rates may apply

Carriers are not liable for delayed or undelivered messages

Supported carriers include AT&T, T-Mobile, Sprint, Verizon, and most regional carriers

SMS Data Protection Statement

No mobile information will be shared with third parties/affiliates for marketing/promotional

purposes. Information sharing to subcontractors in support services, such as customer

service is permitted. All other use case categories exclude text messaging originator opt-in

data and consent; this information will not be shared with any third parties.

We implement strict data protection measures to safeguard your SMS opt-in information and

consent records.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your

information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to

access or store information. Specific information about how we use such technologies and

how you can refuse certain cookies is set out in our Cookie Notice.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in

this privacy notice unless otherwise required by law. We retain your personal information

only as long as necessary to provide our services, fulfill transactions, or comply with legal

obligations. Once we no longer need to retain your information, we will securely delete or

anonymize it.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and

technical security measures.

We have implemented appropriate and reasonable technical and organizational security

measures designed to protect the security of any personal information we process. However,

despite our safeguards and efforts to secure your information, no electronic transmission

over the Internet or information storage technology can be guaranteed to be 100% secure,

so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third

parties will not be able to defeat our security and improperly collect, access, steal, or modify

your information. Although we will do our best to protect your personal information,

transmission of personal information to and from our Services is at your own risk. You should

only access the Services within a secure environment.

7. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.

Withdrawing your consent:

If we are relying on your consent to process your personal information, which may be

express and/or implied consent depending on the applicable law, you have the right to

withdraw your consent at any time. You can withdraw your consent at any time by contacting

us by using the contact details provided in the section "HOW CAN YOU CONTACT US

ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its

withdrawal nor, when applicable law allows, will it affect the processing of your personal

information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications:

You can unsubscribe from our marketing and promotional communications at any time by

clicking on the unsubscribe link in the emails that we send, replying "STOP" or

"UNSUBSCRIBE" to the SMS messages that we send, or by contacting us using the details

provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You

will then be removed from the marketing lists.

You can cancel the SMS service at any time. Simply text "STOP" to the shortcode. Upon

sending "STOP," we will confirm your unsubscribe status via SMS. Following this

confirmation, you will no longer receive SMS messages from us. To rejoin, sign up as you

did initially, and we will resume sending SMS messages to you.

Cookies and similar technologies:

Most Web browsers are set to accept cookies by default. If you prefer, you can usually

choose to set your browser to remove cookies and to reject cookies. If you choose to

remove cookies or reject cookies, this could affect certain features or services of our

Services.

If you have questions or comments about your privacy rights, you may email us at

[email protected]

8. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a

Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference

not to have data about your online browsing activities monitored and collected. At this stage

no uniform technology standard for recognizing and implementing DNT signals has been

finalized. As such, we do not currently respond to DNT browser signals or any other

mechanism that automatically communicates your choice not to be tracked online. If a

standard for online tracking is adopted that we must follow in the future, we will inform you

about that practice in a revised version of this privacy notice.

9. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado or Virginia, you are granted specific

rights regarding access to your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12)

months:

We will use and retain the collected personal information as needed to provide the Services

or for:

Category B - As long as the user has an account with us

We may also collect other personal information outside of these categories through

instances where you interact with us in person, online, or by phone or mail in the context of:

Receiving help through our customer support channels; Participation in customer surveys or

contests; and Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

Learn about how we use your personal information in the section, "HOW DO WE PROCESS

YOUR INFORMATION?"

California Civil Code Section 1798.83, also known as the "Shine The Light" law permits our

users who are California residents to request and obtain from us, once a year and free of

charge, information about categories of personal information (if any) we disclosed to third

parties for direct marketing purposes and the names and addresses of all third parties with

which we shared personal information in the immediately preceding calendar year. If you are

a California resident and would like to make such a request, please submit your request in

writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the

Services, you have the right to request removal of unwanted data that you publicly post on

the Services. To request removal of such data, please contact us using the contact

information provided below and include the email address associated with your account and

a statement that you reside in California. We will make sure the data is not publicly displayed

on the Services, but please be aware that the data may not be completely or

comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

This section applies only to California residents. Under the California Consumer Privacy Act

(CCPA), you have the rights listed below.

The California Code of Regulations defines a "residents" as:

(1) every individual who is in the State of California for other than a temporary or transitory

purpose and(2) every individual who is domiciled in the State of California who is outside the

State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and obligations

regarding your personal information.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your

personal information, we will respect your request and delete your personal information,

subject to certain exceptions provided by law, such as (but not limited to) the exercise by

another consumer of his or her right to free speech, our compliance requirements resulting

from a legal obligation, or any processing that may be required to protect against illegal

activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

whether we collect and use your personal information;

the categories of personal information that we collect;

the purposes for which the collected personal information is used;

whether we sell or share personal information to third parties;

the categories of personal information that we sold, shared, or disclosed for a business purpose;

the categories of third parties to whom the personal information was sold, shared, or

disclosed for a business purpose;

the business or commercial purpose for collecting, selling, or sharing personal information;

and the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer

information that is de-identified in response to a consumer request or to re-identify individual

data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not process consumer's sensitive personal information.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the

same person about whom we have the information in our system. These verification efforts

require us to ask you to provide information so that we can match it with information you

have previously provided us. For instance, depending on the type of request you submit, we

may ask you to provide certain information so that we can match the information you provide

with the information we already have on file, or we may contact you through a

communication method (e.g., phone or email) that you have previously provided to us. We

may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or

authority to make the request. To the extent possible, we will avoid requesting additional

information from you for the purposes of verification. However, if we cannot verify your

identity from the information already maintained by us, we may request that you provide

additional information for the purposes of verifying your identity and for security or

fraud-prevention purposes. We will delete such additionally provided information as soon as

we finish verifying you.

Other privacy rights

You may object to the processing of your personal information.

You may request correction of your personal data if it is incorrect or no longer relevant, or

ask to restrict the processing of the information.

You can designate an authorized agent to make a request under the CCPA on your behalf.

We may deny a request from an authorized agent that does not submit proof that they have

been validly authorized to act on your behalf in accordance with the CCPA.

You may request to opt out from future selling or sharing of your personal information to third

parties.

Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible,

but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by submitting a data subject access request, or

by referring to the contact details at the bottom of this document. If you have a complaint

about how we handle your data, we would like to hear from you.

Colorado Residents

This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), you

have the rights listed below. However, these rights are not absolute, and in certain cases we

may decline your request as permitted by law.

Right to be informed whether or not we are processing your personal data

Right to access your personal data

Right to correct inaccuracies in your personal data

Right to request deletion of your personal data

Right to obtain a copy of the personal data you previously shared with us

Right to opt out of the processing of your personal data if it is used for targeted advertising,

the sale of personal data, or profiling in furtherance of decisions that produce legal or

similarly significant effects ("profiling")

To submit a request to exercise these rights described above, please email

or submit a data subject access request.

If we decline to take action regarding your request and you wish to appeal our decision,

please email us at . Within forty-five (45) days of receipt of an appeal, we will inform you in

writing of any action taken or not taken in response to the appeal, including a written

explanation of the reasons for the decisions.

Connecticut Residents

This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act

(CTDPA), you have the rights listed below. However, these rights are not absolute, and in

certain cases we may decline your request as permitted by law.

Right to be informed whether or not we are processing your personal data

Right to access your personal data

Right to correct inaccuracies in your personal data

Right to request deletion of your personal data

Right to obtain a copy of the personal data you previously shared with us

Right to opt out of the processing of your personal data if it is used for targeted advertising,

the sale of personal data, or profiling in furtherance of decisions that produce legal or

similarly significant effects ("profiling")

To submit a request to exercise these rights described above, please email

or submit a data subject access request.

If we decline to take action regarding your request and you wish to appeal our decision,

please email us at

. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action

taken or not taken in response to the appeal, including a written explanation of the reasons

for the decisions.

Virginia Residents

Under the Virginia Consumer Data Protection Act (VCDPA):

"Consumer" means a natural person who is a resident of the Commonwealth acting only in

an individual or household context. It does not include a natural person acting in a

commercial or employment context.

"Personal data" means any information that is linked or reasonably linkable to an identified

or identifiable natural person. "Personal data" does not include de-identified data or publicly

available information.

"Sale of personal data" means the exchange of personal data for monetary consideration.

If this definition of "consumer" applies to you, we must adhere to certain rights and

obligations regarding your personal data.

Your rights with respect to your personal data

Right to be informed whether or not we are processing your personal data

Right to access your personal data

Right to correct inaccuracies in your personal data

Right to request deletion of your personal data

Right to obtain a copy of the personal data you previously shared with us

Right to opt out of the processing of your personal data if it is used for targeted advertising,

the sale of personal data, or profiling in furtherance of decisions that produce legal or

similarly significant effects ("profiling")

Exercise your rights provided under the Virginia VCDPA

You may contact us by email at or submit a data subject access request.

If you are using an authorized agent to exercise your rights, we may deny a request if the

authorized agent does not submit proof that they have been validly authorized to act on your

behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you

and your consumer's request. If you submit the request through an authorized agent, we

may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within

forty-five (45) days of receipt. The response period may be extended once by forty-five (45)

additional days when reasonably necessary. We will inform you of any such extension within

the initial 45-day response period, together with the reason for the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and

reasoning behind it. If you wish to appeal our decision, please email us at . Within sixty (60)

days of receipt of an appeal, we will inform you in writing of any action taken or not taken in

response to the appeal, including a written explanation of the reasons for the decisions. If

your appeal is denied, you may contact the Attorney General to submit a complaint.

13. Privacy Rights Around the World: What Other Regions Protect

You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set

by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This privacy notice satisfies the notice requirements defined in both Privacy Acts, in

particular: what personal information we collect from you, from which sources, for which

purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable

purpose, it may affect our ability to provide our services, in particular:

offer you the products or services that you want respond to or help with your requests

At any time, you have the right to request access to or correction of your personal

information. You can make such a request by contacting us by using the contact details

provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE

COLLECT FROM YOU?"

If you believe we are unlawfully processing your personal information, you have the right to

submit a complaint about a breach of the Australian Privacy Principles to the Office of the

Australian Information Commissioner and a breach of New Zealand's Privacy Principles to

the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal

information. You can make such a request by contacting us by using the contact details

provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE

COLLECT FROM YOU?"

If you are unsatisfied with the manner in which we address any complaint with regard to our

processing of personal information, you can contact the office of the regulator, the details of

which are:

The Information Regulator (South Africa)

General enquiries: [email protected]

Complaints (complete POPIA/PAIA form 5): [email protected] &

[email protected]

14. CONTACT US

If you have questions about this Privacy Policy or how your information is handled,

contact us at: (619) 919-4956 or email us at: [email protected]

By using our website and services, you consent to this privacy policy.