We collect personal information that varies depending on how you interact with us. Below we describe the types of personal information we may collect and the sources from which we may collect them.

• Account and contact information. When you register for an account, we collect your name, email address, phone number, and any other information you provide during registration or account management.
• Buyer profiles. Our Services enable agents to create and manage buyer profiles on behalf of their clients. Buyer profile data falls into two categories:
  • Internal pipeline data (never publicly displayed):
    • Identity: buyer’s full name. We collect the buyer’s name solely so the agent and authorized members of the agent’s team can identify and manage the buyer within their pipeline. The buyer’s name is never displayed on the published buyer profile, never shared with other agents, sellers, homeowners, or the public, and is accessible only to the agent and their team.
  • Public profile data (displayed on the published, anonymized buyer profile):
    • Location: target search location (city, ZIP code, neighborhood, or address — USA only). This is the buyer’s intentional target search area, provided voluntarily as part of the buyer profile. It is not the user’s current location or device location and is not used for location tracking.
    • Price and financing: maximum offer price, finance types (e.g. conventional, FHA, VA, cash), cash status, loan/pre-approval status, maximum down payment percentage, and maximum earnest money deposit percentage. Financing type is optional and included at the agent’s discretion.
    • Property criteria: minimum bedrooms, bathrooms, square footage, and stories; preferred property types, property conditions, architectural styles, and ownership types.
    • Offer terms and contingencies: home inspection, appraisal, sale, financing, and other inspection contingencies.
    • Timeline: earliest and latest desired move-in dates.
    • Preferences: wishlist of preferred home features grouped by category (e.g. kitchen, outdoor spaces, bedrooms).
    • Profile status: active, unlisted, under contract, purchased, or withdrawn.
• Agent profiles. When setting up or updating an agent profile, we collect:
  • Brokerage information: brokerage name, phone number, and full address (street, city, state, ZIP code, and optional suite/unit).
  • Licensing: US states and territories where the agent is licensed to practice real estate.
  • Contact: work email address and work phone number.
• Agent profile picture. Agents may upload a profile picture, which is displayed on their public agent profile.

We do not collect, solicit, or process the following categories of data through our Services or AI Assistant Integrations:

• Payment card data or information subject to the Payment Card Industry Data Security Standards (PCI DSS), such as credit card numbers, CVV codes, or bank account numbers.
• Protected health information (PHI) as defined under applicable health privacy laws such as HIPAA.
• Government-issued identification numbers, such as Social Security numbers, passport numbers, or driver’s license numbers.
• Access credentials or authentication secrets, such as passwords, API keys, or multi-factor authentication codes.
• Protected-class characteristics, such as race, color, religion, sex, familial status, national origin, disability, sexual orientation, gender identity, or source of income. We do not collect these characteristics and do not use them in ranking, matching, or surfacing buyer profiles.

Whoovia offers integrations with third-party AI assistant platforms (such as ChatGPT and Claude) that allow agents to create and manage buyer profiles, look up profiles, and perform other Whoovia actions using natural language. When you use these integrations, any information you provide through the AI assistant — including all buyer profile fields, agent profile fields, and search queries described in Section 1A above — is transmitted to Whoovia’s servers and processed in the same manner as information submitted through our Site or App.

Specifically, through AI Assistant Integrations we may receive:

• All buyer profile data when creating or updating a buyer profile via the AI assistant — including the buyer’s name (transmitted to Whoovia’s servers as internal pipeline data and never included in the published profile) and all public profile fields (location, price and financing, property criteria, offer terms, timeline, and preferences).
• Agent profile data (brokerage information, licensing jurisdictions, and work contact details) when updating an agent profile via the AI assistant.
• Search queries such as buyer names or agent names used to look up existing profiles.
• Profile identifiers (IDs) submitted when requesting a social media post for a buyer profile. No new personal information is collected in this request; the response is generated from profile data already stored by Whoovia.

Your use of third-party AI assistant platforms is also subject to those platforms’ own privacy policies. We encourage you to review the privacy policies of any AI assistant platform you use to access Whoovia.

• Information provided by buyers, sellers, and/or agents about each other. If you are a seller or buyer who indicates you are working with an agent, your agent may provide information about you, your properties, your profiles, and/or your offers to our Services. Similarly, if you are an agent, the sellers or buyers you work with can submit information about you to our Services; we use that information to contact you and as otherwise described in this Privacy Policy.
• Information about agents. If you are an agent, we may work with your brokerage or third-party partners to verify you are licensed to act on behalf of a buyer and/or seller using our Services. We also may receive information about you from the brokerage with whom you work.
• Owner and property information. We may engage third parties to help us verify property ownership and to provide information about listed properties, such as address verification, bedroom and bathroom counts, interior and exterior features, and other property details.
• Data from other sources. We may obtain personal information from further third-party organizations or from publicly available sources.

• Device and browser data. When you use our Services, certain information about your device and web browser may be automatically collected, such as your IP address, device type, and operating system. You may opt out of this at any time by clicking the “Privacy settings” link in the footer.
• Usage information. We may collect information about how our users use and engage with our Services.
• Cookies and similar technologies. Our Services may use cookies, pixels, or other similar technologies to collect information about your device, your browser, and your activity within the Services.
• Communications. We may collect information about you in connection with requests or inquiries you make to us, whether by email, phone, online submission, or otherwise.

We use the information described above to:

1. Provide our Services to you and others, including creating, publishing, and managing buyer profiles and agent profiles on Whoovia’s buyer discovery platform;
2. Make buyer profiles discoverable to homeowners, sellers, and listing agents, which is the core purpose of our platform;
3. Generate AI-powered content for buyer profiles — including profile taglines, narrative descriptions, agent remarks, and social media posts — by sending relevant profile data to third-party AI content generation services (see Section 4);
4. Process, evaluate, and respond to your requests and inquiries, including questions you submit or other requests you may make;
5. Analyze, evaluate, and improve our Services and technologies; perform data analyses; develop new features; and evaluate user engagement;
6. Market to you and others regarding matters that may be in your interest, including via direct marketing and interest-based advertising within our Services and elsewhere;
7. Personalize the Services we offer to you, including by showing you content or features we think you might like;
8. Protect the safety and integrity of our Services, troubleshoot issues, and detect and prevent errors, fraudulent activity, or other potentially wrongful or harmful activity;
9. Enforce this Privacy Policy or any other contract or agreement we may have with you;
10. Comply with, make claims relating to, or enforce legal rights or obligations, legal process, government requests, or prudent security or business practices.

We also may use information we collect for any other purpose notified to you or to which you consent, or to perform any actions requested by you.

We may share information with third parties for any purpose described in Section 2 above, or for any other purpose that has been notified to you or to which you have consented. This includes sharing information as follows:

1. The general public. When a buyer profile is published on Whoovia, the profile is publicly accessible through our Services in fully anonymized form. The buyer’s name is never displayed publicly. The published profile may include the buyer’s target search area, price range, property criteria, offer terms and contingencies, timeline, preferences, optional financing details (included at the agent’s discretion), and the representing agent’s contact information. Agents are responsible for determining, in their professional judgment and consistent with their duties to their client, what information to include in the published profile.
2. Other agents and platform users. Buyer profiles are shared with other agents and users on the platform for the purpose of facilitating agent-to-agent matches and off-market opportunities.
3. AI content generation service providers. When generating AI-powered content for a buyer profile (such as taglines, narrative descriptions, agent remarks, or social media posts), we transmit relevant profile data — including location, price range, property criteria, financing type, timeline, and preferences — to a third-party AI content generation service. The buyer’s name is never included in data sent to the AI service. This data is used solely to generate the requested content and is subject to that provider’s data processing terms.
4. Buyers, sellers, and their agents. If you indicate you are working with an agent, we may provide information about you to your agent, and vice versa.
5. Our service providers. We may share information with service providers and business partners who provide services to us or otherwise help us operate our business or the Services, such as hosting, analytics, communications, and payment processing providers.
6. As you direct. We may share information with other users or companies to whom you request that we share it.
7. Compliance- and security-related transfers. We may share information in connection with complying with, making claims relating to, or enforcing legal rights or obligations, legal process, government requests, or prudent security or business practices.
8. Business transactions. We may share or transfer information with another business in connection with a merger, acquisition, or sale of our assets.

Whoovia uses artificial intelligence to enhance buyer profiles and generate content on behalf of agents. Specifically:

• Profile content generation. When a buyer profile is created or updated, we automatically generate a profile tagline, narrative description, and agent remarks using a third-party AI service. To do this, we send relevant profile data — including location, price range, property criteria, financing details, move-in timeline, and home preferences — to the AI service. The buyer’s name is never included in data sent to the AI service.
• Social media post generation. When an agent requests a social media post for a buyer profile, we send the profile’s public content and profile URL to a third-party AI service to generate a ready-to-share post written in the agent’s voice.
• AI assistant integrations. Agents may interact with Whoovia through AI assistant platforms (such as ChatGPT or Claude) via our published integrations. In these contexts, the AI assistant platform facilitates the interaction, but the data you provide is processed and stored by Whoovia as described in this Privacy Policy.

We do not use buyer profile data to train AI models. Data sent to third-party AI services for content generation is used solely to fulfill the specific request and is governed by those providers’ data processing agreements with us.

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

• Active accounts. We retain account and profile data for as long as your account remains active or as needed to provide you with our Services.
• Buyer profiles. Buyer profile data is retained for as long as the profile exists in your account. When a buyer profile is deleted, we will remove it from public view immediately and will delete or anonymize the associated personal data within 90 days, except where retention is required for legal, compliance, or fraud prevention purposes.
• Deleted accounts. When you request deletion of your account, we will delete or anonymize your personal information within 90 days of the request, except where retention is required by law or for legitimate business purposes such as resolving disputes or enforcing our agreements.
• Automatically collected data. Usage logs, analytics data, and similar automatically collected information are typically retained for up to 24 months.

You have the following rights and controls with respect to your personal information:

• Access and update. You can view and update your account information and agent profile at any time by logging into your account on our Site or App. You may also update information through our AI Assistant Integrations where applicable.
• Manage buyer profiles. Agents can create, update, and delete buyer profiles directly through the Whoovia web app. Deleting a buyer profile removes it from public view immediately. Profiles can also be set to “Unlisted” to remove them from discovery without permanently deleting the profile data. Buyer profile management is also available through our AI Assistant Integrations.
• Account deletion. You can request deletion of your account and associated personal data by contacting us at [email protected]. We will process your request within 90 days.
• Marketing opt-out. You may opt out of receiving marketing communications from us at any time by following the unsubscribe instructions in any marketing email or by contacting us at [email protected].
• Privacy settings. You may manage certain data collection preferences — such as cookies and device data collection — at any time by clicking the “Privacy settings” link in the footer of our Site.

Depending on your state of residence, you may have specific rights regarding your personal information under laws including the California Consumer Privacy Act (as amended by the CPRA), the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act, the Texas Data Privacy and Security Act, the Oregon Consumer Privacy Act, the Maryland Online Data Privacy Act, and similar laws in other states. These rights may include:

• Right to know / access. The right to confirm whether we process your personal information and to access that information.
• Right to correct. The right to request correction of inaccurate personal information.
• Right to delete. The right to request deletion of your personal information.
• Right to portability. The right to receive a copy of your personal information in a portable format.
• Right to opt out of sale or sharing. The right to opt out of the sale of your personal information or its sharing for cross-context behavioral advertising. You may exercise this right by clicking the “Privacy settings” link in the footer of our Site.
• Right to opt out of targeted advertising. The right to opt out of processing your personal information for targeted advertising. You may exercise this right by clicking the “Privacy settings” link in the footer of our Site.
• Right to opt out of profiling. The right to opt out of automated decision-making that produces legal or similarly significant effects.
• Right to limit use of sensitive personal information. Where applicable, the right to limit our use and disclosure of sensitive personal information.
• Right against discrimination. The right not to receive discriminatory treatment for exercising any of these rights.

To opt out of the sale or sharing of your personal information or targeted advertising, click the “Privacy settings” link in the footer of our Site. For all other requests — including access, correction, deletion, and portability — email us at [email protected]. We will verify your identity before responding, typically by confirming information already associated with your account. You may use an authorized agent to submit a request on your behalf; we may require written authorization and verification of the agent’s identity.

We will respond to verifiable requests within the timeframe required by applicable law (generally 45 days, with the possibility of one extension where permitted).

If we deny your request in whole or in part, you may appeal our decision by replying to our response or by emailing [email protected] with “Privacy Appeal” in the subject line. We will respond to your appeal within 60 days. If your appeal is denied, you may contact your state attorney general.

This section provides additional information for California residents (“consumer” or “you”) and applies to “Personal Information,” as defined by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (the “CCPA”), whether collected online or offline. This section describes our information practices and the rights you may have regarding your Personal Information pursuant to the CCPA.

In the preceding 12 months, we have collected the following categories of personal information from California residents:

• Identifiers
• Internet or other electronic network activity

We collected this information from the following categories of sources:

• Directly from you
• AI assistant platforms (such as ChatGPT and Claude)
• Third-party partners (brokerage verification and property data providers)
• Automatically from your device or browser

We collected and disclosed this information for the following business or commercial purposes:

• Providing and managing our Services, including creating and publishing buyer profiles
• Account management and authentication
• AI content generation for buyer profiles (taglines, descriptions, agent remarks, and social media posts)
• Marketing and promotional communications
• Analytics and product improvement
• Security, fraud detection, and legal compliance

In the preceding 12 months, we disclosed the following categories of personal information to third parties for a business purpose:

• Identifiers
• Internet or other electronic network activity

We do not sell personal information. We share identifiers and internet or electronic network activity with advertising networks and analytics providers for interest-based advertising. You may opt out by clicking the “Privacy settings” link in the footer of our Site or by enabling the Global Privacy Control in your browser.

Consistent with the Maryland Online Data Privacy Act, we limit our collection of personal information to what is reasonably necessary to provide our Services. We do not sell personal information. We do not process the personal information of any known minor under 18 for targeted advertising or sale.

Residents of other states with comprehensive privacy laws — including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Indiana, Tennessee, Delaware, New Hampshire, New Jersey, Kentucky, Minnesota, and Rhode Island — have rights substantially similar to those described above. To exercise any of these rights, contact us at [email protected].

Our Services are intended solely for use by persons 18 years of age or older. If you are under the age of 18, you may not use our Services or contribute any information to us.

Our Services may work with third parties such as advertising networks to provide you with advertisements that you see on our Site or other websites. These parties may use technology that can collect personally identifiable information about your online activities over time and across different websites when you use our Site. To learn more about your ability to opt out, you can visit the Digital Advertising Alliance and the Network Advertising Initiative.

Our Services may contain links to other websites or platforms, including third-party AI assistant platforms. These websites operate independently from us, and their privacy practices are subject to their own privacy notices or policies, which we strongly encourage you to review. We are not responsible for the content of linked websites, any use of those sites, or the privacy practices of those sites.

Where required by applicable law, we honor the Global Privacy Control (GPC) signal as a valid opt-out of the sale or sharing of personal information and of targeted advertising for the browser or device sending the signal. We process GPC signals received through our Site automatically. Note that GPC signals are browser-specific and apply only to data collected through the browser from which the signal is sent.

We may modify this Privacy Policy from time to time and will post any revisions on our Site. We will indicate the Effective Date of the most recent update at the top of this page. By continuing to use our Services following an update, you accept and agree to this Privacy Policy in its updated form.

If you have any questions about this Privacy Policy or our privacy practices, please contact us at [email protected].