PRIVACY POLICY

Last Updated: January 5, 2026

1. Introduction

Propwise REI LLC ("us", "our", "we", "Company") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our websites, including but not limited to soberhomesuccess.com and soberhomeconsultant.com, and use our services (collectively, the "Services").

Data Controller

Propwise REI LLC is the data controller responsible for your personal information.

Contact Information:

Propwise REI LLC

Mailing Address: 8401 Mayland Dr, Ste A, Richmond, VA 23294

Email: [email protected]

Phone: (804)781-4769

Website: soberhomesuccess.com

Scope

This Privacy Policy applies to information we collect through our websites, products, services, and any other interactions you have with us.

Please read this Privacy Policy carefully. By using our Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree with our policies and practices, do not use our Services.

2. Information We Collect

2.1 Personal Information You Provide

We collect personal information that you voluntarily provide to us when you:

Create an account

Purchase our products or services

Sign up for our email list or free content

Contact us for support

Participate in our community or forums

Fill out forms on our website

Types of Personal Information:

Identity Information: First name, last name

Contact Information: Email address, mailing address, phone number

Account Information: Username, password, account preferences

Payment Information: Processed by third-party payment processors (we do not store credit card numbers)

Communication Information: Information you provide in messages to us or in community posts

Professional Information: Information about your sober living operation (if applicable)

2.2 Information Collected Automatically

When you visit our website or use our Services, we automatically collect certain information about your device and usage:

Technical Information:

IP address

Browser type and version

Operating system

Device identifiers

Referring/exit pages

Date and time stamps

Clickstream data

Usage Information:

Pages visited

Time spent on pages

Links clicked

Search queries

Features used

Location Information:

General geographic location based on IP address (city, state, country)

2.3 Information from Third Parties

We may receive information about you from:

Payment Processors: Transaction information from Stripe, PayPal, and other payment processors

Service Providers: Information from HighLevel and other platforms we use to deliver our Services

Affiliates: Information from users who refer you to us

Social Media: If you connect your social media accounts or interact with us on social media

2.4 Cookies and Tracking Technologies

We use cookies, web beacons, pixels, and similar tracking technologies to collect information about your browsing activities. See Section 6 for detailed information about our use of cookies.

3. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, we process your personal information based on the following legal grounds:

Consent: When you have given clear consent for us to process your personal information for a specific purpose (e.g., marketing communications).

Contract: When processing is necessary to perform a contract with you (e.g., providing our Services, processing payments).

Legitimate Interests: When we have a legitimate business interest (e.g., improving our Services, fraud prevention, network security) and your rights do not override these interests.

Legal Obligation: When we must process your information to comply with legal obligations (e.g., tax requirements, legal requests).

You have the right to withdraw consent at any time where we rely on consent as the legal basis for processing.

4. How We Use Your Information

We use your personal information for the following purposes:

4.1 Service Delivery

Create and manage your account

Process transactions and send transaction confirmations

Provide customer support

Deliver products and services you purchase

Send important notices about your account, purchases, or changes to our terms

4.2 Communication

Send marketing and promotional communications (with your consent)

Send newsletters and updates about our products and services

Respond to your inquiries and requests

Send administrative information

You can opt-out of marketing communications at any time by clicking the "unsubscribe" link in our emails or contacting us. You cannot opt-out of transactional or administrative communications that are necessary for service delivery.

4.3 Service Improvement

Analyze usage patterns and trends

Conduct research and analytics

Improve our Services, content, and user experience

Develop new products and features

Test new features and functionality

4.4 Security and Fraud Prevention

Protect against fraud, unauthorized access, and security threats

Verify identity and authenticate users

Monitor and analyze security incidents

Enforce our terms and conditions

4.5 Legal Compliance

Comply with legal obligations

Respond to legal requests and prevent harm

Enforce our rights and protect our property

4.6 Marketing and Advertising

Personalize content and advertisements

Measure advertising effectiveness

Create custom audiences for targeted advertising

Track affiliate activity and pay commissions

5. Third-Party Service Providers

We share your information with third-party service providers who perform services on our behalf. These providers are contractually obligated to use your information only as necessary to provide services to us and to protect your information.

Service Provider Changes: The service providers listed below represent platforms and services we currently use. We reserve the right to change, add, or remove service providers at any time at our sole discretion. When we make significant changes to service providers that handle your personal information, we will update this Privacy Policy.

5.1 HighLevel (CRM and Platform)

We currently use HighLevel as our customer relationship management (CRM) platform and to deliver certain Services to you, including:

Managing your account and contact information

Delivering email and SMS communications

Hosting your business website (if applicable)

Managing workflows and automations

Data Processed by HighLevel:

Your account information

Communications you send and receive through the platform

Any data you input into the system (including information about your residents or clients, if applicable)

HighLevel's Role: HighLevel acts as a data processor on our behalf. Your use of HighLevel features through our Services is subject to HighLevel's terms and policies:

HighLevel Terms of Service: https://www.gohighlevel.com/terms-of-service

HighLevel Privacy Policy: https://www.gohighlevel.com/privacy-policy

HighLevel Acceptable Use Policy: https://www.gohighlevel.com/acceptable-use-policy

Important: Company does not control HighLevel's data handling practices, security measures, or policies. HighLevel's terms govern how your data is collected, stored, and processed on their platform.

5.2 Payment Processors

We use third-party payment processors to process payments, including:

Stripe

PayPal

Other payment service providers

Payment Information:

Payment processors collect and process your payment information directly

We do not store your credit card numbers or full payment details

Your payment information is subject to the payment processor's privacy policy and terms

5.3 Email and Communication Services

We currently use email service providers and communication platforms to send you emails, SMS messages, and other communications, including Kit (formerly ConvertKit) for email marketing and newsletters. These services may track email opens, clicks, and engagement.

5.4 Analytics Providers

We may use third-party analytics and tracking services to understand how our Services are used and to improve user experience. These services may include:

Microsoft Clarity

We may partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising.

For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement: https://privacy.microsoft.com/en-us/privacystatement

Other Analytics Services

We may use other analytics and tracking platforms such as Google Analytics, Facebook Pixel, or similar services to collect information about website usage, user behavior, and advertising effectiveness.

These services may use cookies and similar tracking technologies to collect information about your browsing activities, demographics, and interests.

5.5 Advertising Partners

We work with advertising platforms to deliver targeted advertisements:

Facebook/Meta

Google Ads

Other advertising networks

We may share hashed email addresses or other identifiers to create custom audiences and measure advertising effectiveness.

5.6 Automation and Integration Tools

We use automation tools such as Make.com (formerly Integromat) and other integration platforms to connect our systems and automate workflows. These tools may process your information as part of our service delivery.

5.7 Other Service Providers

Hosting Providers: For website hosting and data storage

Customer Support Tools: For managing customer inquiries

Affiliate Tracking: For tracking referrals and paying commissions

Email Marketing Platforms: For sending newsletters and campaigns

5.8 Artificial Intelligence and Automation Tools

We may use artificial intelligence (AI) and machine learning technologies to improve our Services and provide you with a better experience.

How We Use AI

We may use AI-powered tools and services for purposes including, but not limited to:

Generating or assisting with content creation (emails, templates, documentation)

Analyzing usage patterns and improving user experience

Automating workflows and system processes

Providing customer support responses

Personalizing content and recommendations

Any other purpose related to improving, delivering, or supporting our Services

AI Service Providers

We may use third-party AI services, including but not limited to:

OpenAI (ChatGPT, GPT models)

Anthropic (Claude)

Other AI platforms and tools

Data Processing by AI Services

When we use AI services, certain information may be processed by these services in accordance with their privacy policies and terms of service. We do not use AI to make automated decisions that produce legal or similarly significant effects about you without human involvement.

Your Data and AI

We do not sell your personal information to AI companies

AI-generated content is reviewed before being delivered to you

You retain ownership of any content you provide to us

We do not train third-party AI models on your personal information without your consent

Third-Party AI Policies

If you have questions about how AI service providers handle data, please review their privacy policies:

OpenAI Privacy Policy: https://openai.com/privacy

Anthropic Privacy Policy: https://www.anthropic.com/privacy

Third-Party Privacy Policies and Terms: Each third-party service provider listed in this section operates under their own privacy policy and terms of service. Your use of our Services may be subject to these third-party policies. We do not control and are not responsible for the privacy practices of third parties. We encourage you to review their policies, including:

HighLevel Privacy Policy: https://www.gohighlevel.com/privacy-policy

Microsoft Privacy Statement: https://privacy.microsoft.com/en-us/privacystatement

Stripe Privacy Policy: https://stripe.com/privacy

Kit Privacy Policy: https://convertkit.com/privacy

OpenAI Privacy Policy: https://openai.com/privacy

Anthropic Privacy Policy: https://www.anthropic.com/privacy

Other service providers as applicable

By using our Services, you acknowledge that your information may be processed by these third parties in accordance with their privacy policies.

6. Cookies and Tracking Technologies

6.1 What Are Cookies

Cookies are small text files stored on your device when you visit our website. We use cookies and similar tracking technologies (web beacons, pixels, tags) to collect information about your browsing activities.

6.2 Types of Cookies We Use

Strictly Necessary Cookies

These cookies are essential for our website to function. They enable core functionality such as security, authentication, and accessibility. You cannot opt-out of these cookies.

Performance and Analytics Cookies

These cookies collect information about how you use our website, such as which pages you visit and any errors you encounter. We use this information to improve our website performance.

Google Analytics

Usage tracking and heatmaps

Error reporting

Functionality Cookies

These cookies allow our website to remember your preferences and provide enhanced features.

Language preferences

Login status

Form auto-fill

Advertising and Targeting Cookies

These cookies are used to deliver relevant advertisements and measure advertising effectiveness.

Facebook Pixel

Google Ads

Retargeting pixels

Affiliate tracking

Social Media Cookies

These cookies are set by social media platforms when you interact with social media buttons or plugins on our website.

Facebook

Twitter/X

LinkedIn

YouTube

6.3 How Long Do Cookies Last

Session Cookies: Deleted when you close your browser

Persistent Cookies: Remain on your device for a set period or until you delete them

6.4 Managing Cookies

Browser Settings

You can control cookies through your browser settings. Most browsers allow you to:

View and delete cookies

Block cookies from specific websites

Block all cookies

Delete all cookies when you close your browser

Please note that disabling cookies may affect the functionality of our website and prevent you from using certain features.

Cookie Consent Tools

We provide cookie consent tools that allow you to accept or reject certain categories of cookies (where required by law).

Opt-Out of Targeted Advertising

You can opt-out of targeted advertising:

Browser Settings:

Enable "Do Not Track" or similar settings

Industry Opt-Out Tools:

Digital Advertising Alliance: http://optout.aboutads.info/

Network Advertising Initiative: http://optout.networkadvertising.org/

European Interactive Digital Advertising Alliance (EU): http://www.youronlinechoices.eu/

Platform-Specific Opt-Outs:

Google Ads: https://adssettings.google.com/

Facebook: https://www.facebook.com/settings?tab=ads

Mobile Device Settings

On mobile devices, you can:

iOS: Settings > Privacy > Tracking > Disable "Allow Apps to Request to Track"

Android: Settings > Privacy > Ads > Opt out of Ads Personalization

6.5 Do Not Track Signals

Some browsers include a "Do Not Track" (DNT) feature. Our website does not currently respond to DNT signals because there is no industry standard for how to respond to such signals.

7. How We Share Your Information

We do not sell your personal information to third parties. We may share your information in the following circumstances:

7.1 Service Providers

We share information with third-party service providers who perform services on our behalf (as described in Section 5).

7.2 Affiliates and Referral Partners

If you were referred to us by an affiliate or purchased through a referral link, we may share your email address and purchase information with that affiliate for commission tracking purposes.

7.3 Business Transfers

If Company is involved in a merger, acquisition, sale of assets, bankruptcy, or reorganization, your information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have.

7.4 Legal Requirements

We may disclose your information if required by law or in response to:

Legal process (subpoena, court order, government request)

Legal claims or disputes

Requests from law enforcement or government authorities

Investigations of potential violations of our terms

Protecting the rights, property, or safety of Company, our users, or the public

7.5 With Your Consent

We may share your information for other purposes with your consent or at your direction.

7.6 Aggregated and De-Identified Information

We may share aggregated or de-identified information that cannot reasonably be used to identify you. This information is not considered personal information and may be shared for any purpose.

8. Data Security

We implement reasonable administrative, technical, and physical security measures to protect your personal information from unauthorized access, use, alteration, and destruction.

Security Measures Include:

Encryption of data in transit (SSL/TLS)

Encryption of sensitive data at rest

Access controls and authentication

Regular security assessments

Employee training on data protection

Secure data centers and hosting

No Guarantee

However, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security of your information. You provide information at your own risk.

Your Responsibility

You are responsible for:

Maintaining the confidentiality of your account credentials

Notifying us immediately of any unauthorized access

Using strong passwords

Not sharing your account with others

9. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention Periods:

Active Accounts: While your account is active and for a reasonable period thereafter

Transactional Data: For as long as required for tax, accounting, and legal purposes (typically 7 years)

Marketing Data: Until you opt-out or request deletion

Legal Obligations: As required by applicable law

Inactive Accounts: We may delete or anonymize data from accounts that have been inactive for an extended period

Deletion

When we no longer need your information, we will delete it or anonymize it so it can no longer identify you.

You may request deletion of your account and personal information at any time (subject to legal retention requirements). See Section 11 for information about your rights.

10. International Data Transfers

Company is based in the United States. If you are accessing our Services from outside the United States, please be aware that your information will be transferred to, stored, and processed in the United States.

Data Protection Standards

The United States may not have the same data protection laws as your jurisdiction. By using our Services, you consent to the transfer of your information to the United States.

Safeguards for EEA, UK, and Swiss Users

For users in the European Economic Area, United Kingdom, and Switzerland, we implement appropriate safeguards for international data transfers, including:

Standard Contractual Clauses approved by the European Commission

Adequacy decisions

Other legally approved transfer mechanisms

11. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information.

11.1 Rights for All Users

Access: You can request a copy of the personal information we hold about you.

Correction: You can request that we correct inaccurate or incomplete information.

Deletion: You can request deletion of your personal information (subject to legal retention requirements).

Opt-Out of Marketing: You can opt-out of marketing communications at any time.

11.2 California Privacy Rights (CCPA/CPRA)

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

Right to Know

You have the right to request that we disclose:

Categories of personal information we collected about you

Categories of sources from which we collected personal information

Business or commercial purpose for collecting or selling personal information

Categories of third parties with whom we share personal information

Specific pieces of personal information we collected about you

Categories of personal information we disclosed for a business purpose

Categories of personal information we sold or shared (for targeted advertising)

Right to Delete

You have the right to request deletion of your personal information, subject to certain exceptions (e.g., completing transactions, legal obligations, fraud prevention).

Right to Correct

You have the right to request correction of inaccurate personal information.

Right to Opt-Out

Right to Opt-Out of Sale: You have the right to opt-out of the "sale" of your personal information. Note: We do not sell personal information for monetary consideration.

Right to Opt-Out of Sharing: You have the right to opt-out of "sharing" of personal information for cross-context behavioral advertising (targeted advertising).

Right to Limit Use of Sensitive Personal Information: You have the right to limit our use of sensitive personal information to purposes necessary to provide services.

Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising your CCPA rights.

Authorized Agents

You may designate an authorized agent to submit requests on your behalf. We may require verification of the agent's authority.

Verification

We will verify your identity before processing requests. We may request additional information to verify your identity.

Response Time

We will respond to verifiable requests within 45 days. If we need more time, we will notify you and may take up to 90 days total.

Do Not Sell or Share My Personal Information

To exercise your right to opt-out of the sharing of your personal information for targeted advertising, click here: [Link to opt-out mechanism]

California "Shine the Light" Law

California residents may request information about our disclosure of personal information to third parties for their direct marketing purposes. We do not share personal information with third parties for their own direct marketing purposes.

11.3 Virginia Privacy Rights (VCDPA)

If you are a Virginia resident, you have rights under the Virginia Consumer Data Protection Act similar to CCPA rights, including rights to access, correct, delete, and opt-out of targeted advertising and sale of personal information.

11.4 Colorado Privacy Rights (CPA)

If you are a Colorado resident, you have rights under the Colorado Privacy Act similar to CCPA rights, including rights to access, correct, delete, and opt-out of targeted advertising and sale of personal information.

11.5 Connecticut Privacy Rights (CTDPA)

If you are a Connecticut resident, you have rights under the Connecticut Data Privacy Act similar to CCPA rights, including rights to access, correct, delete, and opt-out of targeted advertising and sale of personal information.

11.6 Utah Privacy Rights (UCPA)

If you are a Utah resident, you have rights under the Utah Consumer Privacy Act similar to CCPA rights, including rights to access, delete, and opt-out of targeted advertising and sale of personal information.

11.7 European Privacy Rights (GDPR)

If you are located in the European Economic Area, United Kingdom, or Switzerland, you have the following rights under the General Data Protection Regulation (GDPR):

Right of Access

You have the right to obtain confirmation of whether we process your personal data and to receive a copy of your personal data.

Right to Rectification

You have the right to have inaccurate personal data corrected and incomplete data completed.

Right to Erasure ("Right to be Forgotten")

You have the right to request deletion of your personal data in certain circumstances, including:

The data is no longer necessary for the purposes for which it was collected

You withdraw consent (where processing is based on consent)

You object to processing and there are no overriding legitimate grounds

The data has been unlawfully processed

Deletion is required for compliance with legal obligations

Right to Restriction of Processing

You have the right to restrict processing of your personal data in certain circumstances, including:

You contest the accuracy of the data

Processing is unlawful and you request restriction instead of erasure

We no longer need the data but you need it for legal claims

You object to processing pending verification of legitimate grounds

Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller (where technically feasible).

Right to Object

You have the right to object to:

Processing based on legitimate interests

Direct marketing (including profiling)

Processing for scientific, historical research, or statistical purposes

Right to Withdraw Consent

Where processing is based on consent, you have the right to withdraw consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

Right to Lodge a Complaint

You have the right to lodge a complaint with your local supervisory authority if you believe we have violated GDPR.

Automated Decision-Making

You have the right not to be subject to decisions based solely on automated processing (including profiling) that produce legal or similarly significant effects, except where necessary for contract performance, authorized by law, or based on explicit consent.

Response Time

We will respond to requests within one month. In complex cases, we may extend this by two additional months and will notify you.

Fees

Requests are generally free. However, we may charge a reasonable fee for excessive, repetitive, or manifestly unfounded requests.

12. How to Exercise Your Rights

To exercise any of your privacy rights, please contact us:

Email: [email protected]

Mail: Propwise REI LLC - 8401 Mayland Dr, Ste A, Richmond, VA 23294

What We Need from You

To process your request, we may need to verify your identity. We may request:

Account email address

Recent transaction information

Government-issued ID (in some cases)

Other information to confirm your identity

Authorized Agents

If you use an authorized agent to submit a request, we may require:

Written authorization from you

Verification of the agent's identity and authority

Direct confirmation from you

Response Time

We will acknowledge your request within 10 business days and respond substantively within:

45 days (with possible 45-day extension) for most requests

30 days for GDPR requests (with possible 60-day extension)

13. Children's Privacy

Our Services are not intended for children under 18 years of age.

No Collection from Children

We do not knowingly collect personal information from children under 18. If you are under 18, do not:

Use our Services

Provide any information to us

Create an account

Parental Consent

If a parent or guardian wishes to purchase our Services for a minor, the parent must:

Create the account using the parent's information

Provide the parent's personal information

Supervise the minor's use of the Services

If We Learn of Collection

If we learn that we have collected personal information from a child under 18 without parental consent, we will delete that information as quickly as possible.

Parents' Rights

If you believe we have collected information from your child, please contact us immediately at [email protected].

14. Third-Party Websites and Services

Our Services may contain links to third-party websites, products, and services that are not owned or controlled by Company.

No Responsibility

We are not responsible for:

The privacy practices of third-party websites

The content of third-party websites

The products or services offered by third parties

Third-Party Privacy Policies

When you click a link to a third-party website, you will be subject to that website's privacy policy. We encourage you to read the privacy policies of any third-party websites you visit.

Social Media Features

Our website may include social media features (e.g., Facebook Like button, Twitter share). These features may collect your IP address, page visited, and may set a cookie. Social media features are governed by the privacy policy of the company providing them.

15. User-Generated Content and Public Forums

Our Services may allow you to post content or participate in community forums that are visible to other users or the public.

Public Information

Any information you post in public areas is public information that can be:

Read, collected, and used by others

Indexed by search engines

Shared and distributed by others

Your Responsibility

You are responsible for:

Any personal information you choose to share publicly

The content you post

Protecting your privacy in public forums

Our Rights

We reserve the right to:

Monitor public forums

Remove content that violates our terms

Use publicly posted content for our business purposes

Recommendation

We recommend you do not share sensitive personal information in public forums.

16. Marketing Communications

16.1 Email Marketing

With your consent (or where permitted by law), we may send you marketing emails about:

New products and features

Special offers and promotions

Educational content and tips

Company news and updates

CAN-SPAM Compliance

We comply with the CAN-SPAM Act. Our marketing emails include:

Clear identification that the message is an advertisement

Our physical address

A clear way to opt-out (unsubscribe link)

Honor of opt-out requests within 10 business days

Unsubscribe

You can opt-out of marketing emails at any time by:

Clicking the "unsubscribe" link in any email

Updating your email preferences in your account settings

Emailing us at [email protected]

Transactional Emails

You cannot opt-out of transactional emails necessary for service delivery (e.g., purchase confirmations, account notifications).

16.2 SMS Marketing

If you opt-in to receive SMS messages from us, we will send you:

Marketing promotions

Updates about your account

Service notifications

TCPA Compliance

We comply with the Telephone Consumer Protection Act (TCPA). You must provide express written consent to receive marketing SMS messages.

Opt-Out of SMS

You can stop receiving SMS messages at any time by:

Replying "STOP" to any SMS message

Contacting us at [email protected]

Message and Data Rates

Message and data rates may apply. Message frequency varies.

17. Automated Decision-Making and Profiling

We may use automated systems to analyze your information to:

Personalize your experience

Recommend relevant content

Improve our Services

Detect fraud

No Solely Automated Decisions

We do not make decisions that produce legal or similarly significant effects based solely on automated processing without human involvement.

Your Rights

If you are in the EEA, UK, or Switzerland, you have the right to object to automated decision-making and to request human review of automated decisions.

18. California Residents - Additional Disclosures

18.1 Categories of Personal Information

In the past 12 months, we have collected the following categories of personal information (as defined by CCPA):

Identifiers: Name, email address, IP address, account username

Commercial Information: Purchase history, transaction records

Internet Activity: Browsing history, search history, interaction with our website

Geolocation Data: General location based on IP address

Professional Information: Information about your business

Inferences: Preferences and characteristics derived from other information

18.2 Sources of Personal Information

We collect personal information from:

Directly from you

Automatically through your use of our Services

From third parties (affiliates, service providers, social media)

18.3 Purposes for Collection

We collect personal information for the purposes described in Section 4.

18.4 Disclosure of Personal Information

We disclose personal information to the categories of third parties described in Section 7.

18.5 Sale or Sharing of Personal Information

Sale: We do not sell personal information for monetary consideration.

Sharing for Targeted Advertising: We may share certain identifiers with advertising partners for targeted advertising purposes. You can opt-out as described in Section 11.2.

18.6 Sensitive Personal Information

We do not collect or use sensitive personal information (as defined by CPRA) except as necessary to provide our Services or as permitted by law.

18.7 Retention

We retain personal information as described in Section 9.

19. Nevada Residents

Nevada residents have the right to opt-out of the sale of certain covered information. We do not sell covered information as defined by Nevada law. If you are a Nevada resident and have questions, please contact us at [email protected].

20. Data Breach Notification

In the event of a data breach that compromises your personal information, we will:

Notification to Users

Notify affected users without undue delay and, where feasible, within 72 hours of becoming aware of the breach (or as required by applicable law).

Notification Method

We will notify you by:

Email to the address associated with your account

Notice on our website

Other means as appropriate

Information Provided

Our notification will include:

Nature of the breach

Types of information affected

Steps we are taking to address the breach

Steps you can take to protect yourself

Contact information for questions

Notification to Authorities

We will notify relevant authorities as required by law.

21. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

Notification of Changes

We will notify you of material changes by:

Updating the "Last Updated" date at the top of this Privacy Policy

Sending an email notification to the address associated with your account (for significant changes)

Posting a prominent notice on our website

Other means as appropriate

Review of Changes

We encourage you to review this Privacy Policy periodically. The "Last Updated" date indicates when the Privacy Policy was last revised.

Acceptance of Changes

Your continued use of our Services after changes are posted constitutes your acceptance of the updated Privacy Policy.

Material Changes

If we make material changes that significantly affect your rights, we will provide more prominent notice and, where required by law, obtain your consent.

22. Contact Us

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

General Inquiries:

Email: [email protected]

Mail: Propwise REI LLC - 8401 Mayland Dr, Ste A, Richmond, VA 23294

Privacy-Specific Inquiries:

For privacy-specific questions or to exercise your privacy rights, please contact our privacy team at: [email protected]

Response Time

We will respond to your inquiry within a reasonable timeframe, typically within 30 days.

European Users

If you are located in the European Economic Area, United Kingdom, or Switzerland:

Email: [email protected]

You also have the right to lodge a complaint with your local supervisory authority if you believe we have violated GDPR.

Escalation

If you are unsatisfied with our response, you may escalate your concern to:

Your local data protection authority (for EEA, UK, Swiss residents)

The California Attorney General (for California residents)

Other relevant regulatory authorities in your jurisdiction

23. Additional Information

23.1 Commitment to Privacy

Company is committed to:

Transparency in our data practices

Protecting your personal information

Complying with applicable privacy laws

Respecting your privacy rights

Continuously improving our privacy practices

23.2 Employee Training

We train our employees on:

Privacy policies and procedures

Data security best practices

Handling of personal information

Compliance with privacy laws

23.3 Privacy by Design

We implement privacy considerations into:

Product development

Service design

Business processes

Technology infrastructure

23.4 Regular Reviews

We regularly review and update:

Our privacy practices

Security measures

Service provider agreements

Compliance with evolving privacy laws

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