Cuentra Privacy Policy
Cuentra Privacy Policy
Last Updated: January 7, 2026
PRIVACY POLICY
This Privacy Policy ("Policy") explains how Cuentra LLC and our affiliates (collectively, "Cuentra", "we", "us" or "our") collects, stores, uses, and discloses personal data about you, how we use it, how and when it may be shared, the rights and choices you have with respect to your personal data, how we communicate with you and how you can make requests or submit inquiries to us about your personal data. Capitalized terms used but not defined herein have the meaning set forth in our Terms of Service.
CONTENTS
About Us
What Does This Policy Cover
How Is This Policy Updated
Information We Collect
How We Use Your Personal Data
Disclosure of Personal Data
How We Protect Your Personal Data
Cookies and Other Information Collection Tools
Social Media and Other Third-Party Links and Services
Retention of Personal Data
Your Privacy Rights and Choices
Children's Privacy
Contact Us
ABOUT US
Cuentra is a community platform that connects real estate buyers, sellers, and other Users who may be involved in or assist with the real estate buying and selling process directly, without the use of traditional agents or brokers. Users can create listings, communicate with prospective buyers or sellers, and access tools to support the transaction process.
WHAT DOES THIS POLICY COVER
This Policy applies to personal data we collect both online and offline, including personal data we collect through our websites, such as www.cuentra.co and any successor website (collectively the "Sites"), in connection with any of our mobile applications and other products and services we provide you that reference this Policy (together with the Sites, the "Services"), and any other interactions you may have with us including at or through conferences, events, visits to our offices, electronic newsletters or communications.
In this Policy, "personal data" means any information that identifies, relates to, describes, is reasonably capable of being associated with or reasonably can be used to identify an individual or household and other data that is linked to personal data or is otherwise defined as "personal data," "personal information," or "personally identifiable information" by applicable laws.
This Policy does not apply to any products, services, websites, or content that are offered by third parties or have their own privacy policy.
HOW IS THIS POLICY UPDATED
We may modify this Policy from time to time. If we make changes, we will revise the "Last Updated" date at the top of the Policy on our Sites and use reasonable efforts to provide you additional notification, such as by sending you an email notification. We encourage you to review this Policy each time you visit our Sites or use our Services to stay informed of our privacy practices and the choices available to you.
INFORMATION WE COLLECT
The personal data we collect about you depends on how you interact with us or use our Services. We describe below the categories of personal data we collect and the sources of this information.
Information You Provide to Us
We collect personal data from you when you use our Services, send us an email, fill out a form, subscribe to our newsletter, respond to a survey, interact with us on social media, or otherwise communicate with us.
Types of personal data we may collect include:
• Contact information such as your first and last name, email address, telephone number, and mailing address;
• Government-issued identification such as social security number, driver's license, or state-issued identification number;
• Information relating to homes you are looking to buy or sell such as:
- Photographic and video recordings of your home, together with any metadata embedded in such files;
- Property identification details like Assessor's Parcel Number (APN);
- Information regarding monthly Homeowners Association dues, including amounts and payment records;
- Sales documentation like offer letters, property, pest, roof, and pool inspection reports, disclosures, and title reports, proof of funds, financing approval, letter of introduction;
- Information about any property website you have created to market or showcase the property;
• Payment Information such as your credit card or bank account number, which we may share with third-party payment processors as described in this Policy;
• Financial Information such as your income, assets, liabilities, or other financial account details relevant to your capacity to purchase real estate;
• Communications with other Users such as messages, inquiries, or other communications you send to or receive from other Users through our Services;
• Communications with us including through meetings with our representatives, visits to our offices, presentations by us, website forms, and contact with our service;
• Social and community content such as posts, photos, videos, or audio files that you may provide through our social media pages, forums, and our community pages; and
• Any additional Information that you choose to provide to us or our Network Providers through the Services.
We may collect and display User Content, including text, photos, videos, reviews, feedback, tips, or other materials. This includes, for example, (i) service providers who submit written tips or video content that we may post on the Services, (ii) buyers or sellers who share information about their property on our community pages or in our forums, and (iii) prospective buyers who provide feedback or reviews about homes they have toured. Please note that any User Content you submit may be publicly available to other Users of the Services.
In some cases, we may also collect information you provide about others. We will use this information to fulfill your requests and will not send communications to your contacts unrelated to your requests unless they separately create an account, engage with us or consent to receive communications from us.
Information Collected Automatically When You Interact With Us
We and our service providers may automatically log personal data about you, your computer or mobile device, and your interaction over time with the Services, such as:
• Device information. We may collect information about your device(s) such as Internet Protocol ("IP") addresses, browser type and version, domain names, access times, log information, error messages, device type, unique device identifiers, operating system, information about your use of the Site, data regarding network connected hardware and other technical information such as protocol status and sub-status, bytes sent and received and server information.
• Transaction Information. We may collect information when you conduct transactions through our Services.
• Pseudonymous Identifiers. We may collect pseudonymous identifiers such as unique cookie and device identifiers (as described further below), mobile device identifiers, other identifiers derived from email address, or phone numbers, or your device information.
• Usage information. We may collect information about your use of the Services, such as the pages you viewed, the Services you used or interacted with, clicks, mouse movements, scrolling behavior, keystrokes and browsing session data, referring website addresses and details about any links or communications with which you interacted.
• Information Collected by Cookies and Other Tracking Technologies. Please see our cookie policy in the section "Cookies and Other Information Collection Tools" for more details on the information we and our service providers collect about you.
• Marketing and Preferences Information. We may collect information about your preferences for receiving communications from us, your responses to surveys, promotions, or offers, and your interactions with our marketing materials.
• Geolocation Information. We may automatically collect approximate or precise location data from your device or IP address, depending on your device and app settings.
• Log and Diagnostic Information. We may automatically collect technical logs and diagnostic data, such as error reports, crash dumps, performance data, and information about how the Services are functioning.
Information We Collect From Other Sources
We may also collect personal data about you from other sources, including, for example, publicly available databases and our Network Providers (as defined below), and combine that with information we collect through the Services. For example, we may use cookies, tracking pixels or similar technologies to conduct analytics of our Sites, and we, our service providers and third-party services may automatically collect information about your usage of the Sites, including, for example, the areas or pages you visit, the amount of time spent on the Sites, the number of times you return to the Sites, and other related usage data.
In addition, as part of our identity verification process, we may receive limited information collected by our third-party provider (currently Stripe) through their ID verification flow, including captured images of your ID document, selfies, extracted data from your ID document, keyed-in information, and verification result. We use this information to verify your identity and confirm that you are who you say you are.
Information We Infer or Derive
We may derive information or draw inferences about you based on the personal data we collect or have otherwise received about you.
HOW WE USE YOUR PERSONAL DATA
Depending on how you interact with us and the Services you or your organization utilize, we use your personal data to:
• Provide and Improve Products and Services. Provide, activate, operate, maintain, develop, enhance, improve, support, troubleshoot, and manage our Services and your accounts on our Services, monitor and analyze trends, usage, and activities, and to perform services requested by you, including to provide maintenance recommendations, performance tips, and delivery of software updates for such Services;
• Respond to You. Provide Services support and respond to your requests, inquiries, comments and concerns;
• Service Communications. Notify you about changes, updates and other announcements related to our Services and send you technical notices, updates, security alerts, safety and support messages, and other transactional or relationship messages;
• Personalize Your Experience. Customize our Service offerings and present you with tailored content and recommendations from us and our third-party partners such as our Network Providers, and otherwise personalize your experience while using our Services;
• Events and Offers. To facilitate events, contests, promotions and sweepstakes, and process and deliver entries, rewards, and prizes;
• Safety and Security. For safety and security, including to detect and protect against fraud or illegal activities, security incidents, and harm to rights, property or safety of Cuentra, Users of our Services or others;
• Advertising and Marketing. To provide you with advertising, promotional messages and other information about products, events and services of ours, our affiliates and third parties, such as event sponsors and Network Providers;
• Research and Development. To conduct research and development and develop new products and services;
• Corporate Transactions. We process personal data in the context of a merger, consolidation, reorganization, sale of our assets, financing or acquisition of all or a portion of our business to another company, or other corporate transactions;
• Comply with Legal and Financial Obligations. To comply with our legal and financial obligations (including complying with court orders, discovery requests, subpoenas and other legal obligations), resolve disputes, enforce our agreements, and exercise our legal rights;
• Your Consent. Process your personal data in accordance with your consent or when you intentionally direct or instruct us to do so; and
• Other Notified Purposes. Carry out any other purpose conveyed to you at the time the information was collected.
DISCLOSURE OF PERSONAL DATA
We may disclose your personal data as follows or as otherwise described in this Policy:
• Affiliates and Subsidiaries. We disclose your personal data to our affiliates and other organizations under common control for the purposes described in this Policy;
• Third Parties You Intentionally Interact With. We disclose your personal data to third parties (including our Network Providers) when you use our Services to intentionally interact with those third parties or direct us to interact with those third parties;
• Vendors and Service Providers. We disclose your personal data to our vendors and service providers to perform the functions for which we engage them;
• Corporate Transactions. We disclose your personal data as part of, in connection with, or during negotiations of, any merger, sale of our assets, financing or acquisition of all or a portion of our business to another company, or other corporate transactions;
• Analytics Providers. We disclose personal data to our analytics partners, such as PostHog (you can read more about our use of PostHog in the Cookies and Other Information Collection Tools section below);
• Professional Advisors. We disclose your personal data to our professional advisors like our lawyers, accountants, financial, insurance and other advisors in connection with the management of all or a part of our business or operations;
• Third-Party Partners. We disclose your personal data to unaffiliated third-party companies we partner with that provide certain services or experiences to you, including photographers, home design and staging experts and home repair professionals (our "Network Providers");
• Information Shared for Third-Party Marketing. We may share your personal data with third parties for their own direct marketing purposes, as permitted by law. You may opt-out by contacting us;
• Aggregated, Anonymized, or De-Identified. We disclose aggregated, anonymized, or de-identified information, which cannot reasonably be used to identify you;
• Law Enforcement and Individuals Involved in Legal Proceedings. We disclose your personal data when we believe doing so is reasonably necessary to comply with applicable law or legal process or other legal reasons, including:
- When we reasonably believe disclosure is required to comply with a subpoena, court order, or other applicable law, regulation or legal process;
- To enforce, remedy, or apply our agreements and contractual rights;
- To protect our property (including intellectual property) or protect the rights, property or safety of others;
- To support external auditing, compliance and corporate governance functions; and
- To prevent, detect, and remedy fraud, cybersecurity attacks or illegal activity.
• With your Consent or Direction. We disclose personal data with your consent or at your direction, including if we notify you that your personal data will be shared in a particular manner and you provide such personal data.
HOW WE PROTECT YOUR PERSONAL DATA
We implement commercially reasonable physical, technical and procedural measures to help protect personal data from unauthorized access or use; however, the transmission of information via the internet is not completely secure or private. If you have questions about the security of personal data we collect, please contact us using the information provided below.
COOKIES AND OTHER INFORMATION COLLECTION TOOLS
What are cookies? A cookie is a small file containing a string of characters that is sent to your computer when you visit a website or use an online service. When you visit the website or use the online service again, the cookie allows that website or online service to recognize your browser or device. Cookies may store unique identifiers, user preferences and other information.
The type of cookies we may use include:
Necessary Cookies. These cookies are strictly necessary to make our Services function properly. These cookies ensure basic functionalities and security features of the Sites.
Functional Cookies. Functional cookies help to perform certain functionalities like sharing the content of the Sites on social media platforms, collect feedback, and other third-party features.
Performance Cookies. Performance cookies are used to understand and analyze the key performance indexes of the Sites which helps in delivering a better user experience for the visitors.
Analytics Cookies. Analytical cookies are used to understand how visitors interact with the Sites. These cookies help provide information on metrics, the number of visitors, bounce rate, traffic source, etc.
Advertisement Cookies. Advertisement cookies are used to provide visitors with relevant ads and marketing campaigns. These cookies track visitors across websites and collect information to provide customized ads.
Duration of Cookies. We may use "session cookies" or "persistent cookies." Session cookies are temporary and expire once you close your browser or once your session ends. Persistent cookies remain on your device for much longer or until you or your browser erases them. Persistent cookies have varying durations that are dependent on their expiration date.
Why do we use them? We and our business partners use cookies to collect information about you so we can provide the experiences you request, recognize your visit, track your interactions, improve your experience and detect and prevent fraud. We may use cookies provided by third-party partners such as analytics providers, customer relationship management platforms, or payment processors.
How do I control cookies? You can limit online tracking by:
• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
Do Not Track. Some Internet browsers can be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit allaboutdnt.com.
Where required by applicable law, we obtain your consent prior to placing or using optional cookies that are not (i) strictly necessary to provide the Site or the Services e.g., Necessary Cookies; or (ii) for the purpose of facilitating a communication.
Analytics Cookies. We currently use PostHog to provide us with analytics data relating to how you use our Services and provide marketing and advertising to you. You can learn more about how PostHog processes your personal data by visiting https://posthog.com/privacy. To manage or opt out of analytics tracking, you can adjust your browser settings to block or delete cookies, or use third-party tools that control cookie tracking.
SOCIAL MEDIA AND OTHER THIRD-PARTY LINKS AND SERVICES
Third Party Partners
Occasionally, at our discretion, we may include or offer third party products or services on our Sites or links to other websites including by connecting you with, or recommending the services of, our Network Providers. We also currently use Docusign for electronic signature processing and Stripe for identity verification and payment processing. In the future, we may engage additional partners to provide these or similar services. The privacy practices of these third parties will be governed by the parties' own privacy notices. We are not responsible for the security or privacy of any information collected by these third parties, except in the event such parties disclose such information to us, in which case this Policy will apply. You should review the privacy notices or policies applicable to these third-party products and/or services. We have no responsibility or liability for the content and activities of these linked websites or the services they provide.
Social Media
Some aspects of the Sites may allow you to interface with social media services such as Facebook, Instagram, LinkedIn, and X (formerly known as Twitter®). By using these interfaces, you will allow us to access information about you from those social media services, including information and other content that you submit to those social media services. For a description on how such social media services and other third-party platforms, plug-ins, integrations, and applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings with that service or platform.
Use of AI Services.
Our Services use artificial intelligence (AI) services (provided by third-party vendors), including to assist Users with general inquiries and navigation and to draft content for Users to display in our Services. When you interact with our AI chat features, you acknowledge that you are communicating with artificial intelligence and (i) your messages may be processed by third-party AI providers (such as Google or OpenAI) and (ii) we will process any of your personal data shared in chat according to this Policy, but the third-party AI provider will process your personal data in accordance with their own privacy policies and we are not liable for their handling of your personal data.
RETENTION OF PERSONAL DATA
We will retain your personal data for as long as is necessary to fulfil the purpose for which this data was collected and for the business purposes explained in this Policy.
Even after we stop providing Services directly to you, and even if you close your account, we may retain your personal data to the extent permitted by applicable law:
• to comply with our legal and regulatory obligations;
• to protect against fraudulent or abusive activity on our Service; or
• to exercise, establish or defend legal claims.
In cases where we keep personal data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law. Our retention periods will vary depending on the type of data involved, but generally, to determine the appropriate retention period for personal data, we consider:
• the amount, nature, and sensitivity of the personal data;
• the potential risk of harm from unauthorized use or disclosure of your personal data;
• whether such information is needed to provide services;
• whether there is a contractual or legal need to retain the data;
• the purposes for which we process your personal data and whether we can achieve such purposes through other means; and
• applicable legal requirements.
YOUR PRIVACY RIGHTS AND CHOICES
You may opt out of receiving direct marketing communications from us by following the unsubscribe instructions in those communications, visiting our unsubscribe page, or by contacting us as set forth below.
If you contact us to exercise the opt-out of direct marketing right, please note that we may only implement requests with respect to the personal data associated with you as an individual. We may need to verify your identity before implementing your request and will try to comply with your request as soon as reasonably practicable and in accordance with the timelines required under applicable law. If we cannot verify your identity or your ownership rights to the data, we may not be able to service your request until you provide proper documentation.
Please note that there are certain communications we are required to send you that relate to the Services we are providing to you or the organization you represent that you may not be able to opt out of (e.g., support and important legal notices).
CHILDREN'S PRIVACY
Our Services are not aimed at children under the age of 18 or the age defined under applicable law. We do not intentionally collect information from children under the age of 18 or the age defined under applicable law.
CONTACT US
If you have any questions about this Policy or feedback about our Services, you may contact us at privacy@cuentra.co.
Last Updated: January 7, 2026
PRIVACY POLICY
This Privacy Policy ("Policy") explains how Cuentra LLC and our affiliates (collectively, "Cuentra", "we", "us" or "our") collects, stores, uses, and discloses personal data about you, how we use it, how and when it may be shared, the rights and choices you have with respect to your personal data, how we communicate with you and how you can make requests or submit inquiries to us about your personal data. Capitalized terms used but not defined herein have the meaning set forth in our Terms of Service.
CONTENTS
About Us
What Does This Policy Cover
How Is This Policy Updated
Information We Collect
How We Use Your Personal Data
Disclosure of Personal Data
How We Protect Your Personal Data
Cookies and Other Information Collection Tools
Social Media and Other Third-Party Links and Services
Retention of Personal Data
Your Privacy Rights and Choices
Children's Privacy
Contact Us
ABOUT US
Cuentra is a community platform that connects real estate buyers, sellers, and other Users who may be involved in or assist with the real estate buying and selling process directly, without the use of traditional agents or brokers. Users can create listings, communicate with prospective buyers or sellers, and access tools to support the transaction process.
WHAT DOES THIS POLICY COVER
This Policy applies to personal data we collect both online and offline, including personal data we collect through our websites, such as www.cuentra.co and any successor website (collectively the "Sites"), in connection with any of our mobile applications and other products and services we provide you that reference this Policy (together with the Sites, the "Services"), and any other interactions you may have with us including at or through conferences, events, visits to our offices, electronic newsletters or communications.
In this Policy, "personal data" means any information that identifies, relates to, describes, is reasonably capable of being associated with or reasonably can be used to identify an individual or household and other data that is linked to personal data or is otherwise defined as "personal data," "personal information," or "personally identifiable information" by applicable laws.
This Policy does not apply to any products, services, websites, or content that are offered by third parties or have their own privacy policy.
HOW IS THIS POLICY UPDATED
We may modify this Policy from time to time. If we make changes, we will revise the "Last Updated" date at the top of the Policy on our Sites and use reasonable efforts to provide you additional notification, such as by sending you an email notification. We encourage you to review this Policy each time you visit our Sites or use our Services to stay informed of our privacy practices and the choices available to you.
INFORMATION WE COLLECT
The personal data we collect about you depends on how you interact with us or use our Services. We describe below the categories of personal data we collect and the sources of this information.
Information You Provide to Us
We collect personal data from you when you use our Services, send us an email, fill out a form, subscribe to our newsletter, respond to a survey, interact with us on social media, or otherwise communicate with us.
Types of personal data we may collect include:
• Contact information such as your first and last name, email address, telephone number, and mailing address;
• Government-issued identification such as social security number, driver's license, or state-issued identification number;
• Information relating to homes you are looking to buy or sell such as:
- Photographic and video recordings of your home, together with any metadata embedded in such files;
- Property identification details like Assessor's Parcel Number (APN);
- Information regarding monthly Homeowners Association dues, including amounts and payment records;
- Sales documentation like offer letters, property, pest, roof, and pool inspection reports, disclosures, and title reports, proof of funds, financing approval, letter of introduction;
- Information about any property website you have created to market or showcase the property;
• Payment Information such as your credit card or bank account number, which we may share with third-party payment processors as described in this Policy;
• Financial Information such as your income, assets, liabilities, or other financial account details relevant to your capacity to purchase real estate;
• Communications with other Users such as messages, inquiries, or other communications you send to or receive from other Users through our Services;
• Communications with us including through meetings with our representatives, visits to our offices, presentations by us, website forms, and contact with our service;
• Social and community content such as posts, photos, videos, or audio files that you may provide through our social media pages, forums, and our community pages; and
• Any additional Information that you choose to provide to us or our Network Providers through the Services.
We may collect and display User Content, including text, photos, videos, reviews, feedback, tips, or other materials. This includes, for example, (i) service providers who submit written tips or video content that we may post on the Services, (ii) buyers or sellers who share information about their property on our community pages or in our forums, and (iii) prospective buyers who provide feedback or reviews about homes they have toured. Please note that any User Content you submit may be publicly available to other Users of the Services.
In some cases, we may also collect information you provide about others. We will use this information to fulfill your requests and will not send communications to your contacts unrelated to your requests unless they separately create an account, engage with us or consent to receive communications from us.
Information Collected Automatically When You Interact With Us
We and our service providers may automatically log personal data about you, your computer or mobile device, and your interaction over time with the Services, such as:
• Device information. We may collect information about your device(s) such as Internet Protocol ("IP") addresses, browser type and version, domain names, access times, log information, error messages, device type, unique device identifiers, operating system, information about your use of the Site, data regarding network connected hardware and other technical information such as protocol status and sub-status, bytes sent and received and server information.
• Transaction Information. We may collect information when you conduct transactions through our Services.
• Pseudonymous Identifiers. We may collect pseudonymous identifiers such as unique cookie and device identifiers (as described further below), mobile device identifiers, other identifiers derived from email address, or phone numbers, or your device information.
• Usage information. We may collect information about your use of the Services, such as the pages you viewed, the Services you used or interacted with, clicks, mouse movements, scrolling behavior, keystrokes and browsing session data, referring website addresses and details about any links or communications with which you interacted.
• Information Collected by Cookies and Other Tracking Technologies. Please see our cookie policy in the section "Cookies and Other Information Collection Tools" for more details on the information we and our service providers collect about you.
• Marketing and Preferences Information. We may collect information about your preferences for receiving communications from us, your responses to surveys, promotions, or offers, and your interactions with our marketing materials.
• Geolocation Information. We may automatically collect approximate or precise location data from your device or IP address, depending on your device and app settings.
• Log and Diagnostic Information. We may automatically collect technical logs and diagnostic data, such as error reports, crash dumps, performance data, and information about how the Services are functioning.
Information We Collect From Other Sources
We may also collect personal data about you from other sources, including, for example, publicly available databases and our Network Providers (as defined below), and combine that with information we collect through the Services. For example, we may use cookies, tracking pixels or similar technologies to conduct analytics of our Sites, and we, our service providers and third-party services may automatically collect information about your usage of the Sites, including, for example, the areas or pages you visit, the amount of time spent on the Sites, the number of times you return to the Sites, and other related usage data.
In addition, as part of our identity verification process, we may receive limited information collected by our third-party provider (currently Stripe) through their ID verification flow, including captured images of your ID document, selfies, extracted data from your ID document, keyed-in information, and verification result. We use this information to verify your identity and confirm that you are who you say you are.
Information We Infer or Derive
We may derive information or draw inferences about you based on the personal data we collect or have otherwise received about you.
HOW WE USE YOUR PERSONAL DATA
Depending on how you interact with us and the Services you or your organization utilize, we use your personal data to:
• Provide and Improve Products and Services. Provide, activate, operate, maintain, develop, enhance, improve, support, troubleshoot, and manage our Services and your accounts on our Services, monitor and analyze trends, usage, and activities, and to perform services requested by you, including to provide maintenance recommendations, performance tips, and delivery of software updates for such Services;
• Respond to You. Provide Services support and respond to your requests, inquiries, comments and concerns;
• Service Communications. Notify you about changes, updates and other announcements related to our Services and send you technical notices, updates, security alerts, safety and support messages, and other transactional or relationship messages;
• Personalize Your Experience. Customize our Service offerings and present you with tailored content and recommendations from us and our third-party partners such as our Network Providers, and otherwise personalize your experience while using our Services;
• Events and Offers. To facilitate events, contests, promotions and sweepstakes, and process and deliver entries, rewards, and prizes;
• Safety and Security. For safety and security, including to detect and protect against fraud or illegal activities, security incidents, and harm to rights, property or safety of Cuentra, Users of our Services or others;
• Advertising and Marketing. To provide you with advertising, promotional messages and other information about products, events and services of ours, our affiliates and third parties, such as event sponsors and Network Providers;
• Research and Development. To conduct research and development and develop new products and services;
• Corporate Transactions. We process personal data in the context of a merger, consolidation, reorganization, sale of our assets, financing or acquisition of all or a portion of our business to another company, or other corporate transactions;
• Comply with Legal and Financial Obligations. To comply with our legal and financial obligations (including complying with court orders, discovery requests, subpoenas and other legal obligations), resolve disputes, enforce our agreements, and exercise our legal rights;
• Your Consent. Process your personal data in accordance with your consent or when you intentionally direct or instruct us to do so; and
• Other Notified Purposes. Carry out any other purpose conveyed to you at the time the information was collected.
DISCLOSURE OF PERSONAL DATA
We may disclose your personal data as follows or as otherwise described in this Policy:
• Affiliates and Subsidiaries. We disclose your personal data to our affiliates and other organizations under common control for the purposes described in this Policy;
• Third Parties You Intentionally Interact With. We disclose your personal data to third parties (including our Network Providers) when you use our Services to intentionally interact with those third parties or direct us to interact with those third parties;
• Vendors and Service Providers. We disclose your personal data to our vendors and service providers to perform the functions for which we engage them;
• Corporate Transactions. We disclose your personal data as part of, in connection with, or during negotiations of, any merger, sale of our assets, financing or acquisition of all or a portion of our business to another company, or other corporate transactions;
• Analytics Providers. We disclose personal data to our analytics partners, such as PostHog (you can read more about our use of PostHog in the Cookies and Other Information Collection Tools section below);
• Professional Advisors. We disclose your personal data to our professional advisors like our lawyers, accountants, financial, insurance and other advisors in connection with the management of all or a part of our business or operations;
• Third-Party Partners. We disclose your personal data to unaffiliated third-party companies we partner with that provide certain services or experiences to you, including photographers, home design and staging experts and home repair professionals (our "Network Providers");
• Information Shared for Third-Party Marketing. We may share your personal data with third parties for their own direct marketing purposes, as permitted by law. You may opt-out by contacting us;
• Aggregated, Anonymized, or De-Identified. We disclose aggregated, anonymized, or de-identified information, which cannot reasonably be used to identify you;
• Law Enforcement and Individuals Involved in Legal Proceedings. We disclose your personal data when we believe doing so is reasonably necessary to comply with applicable law or legal process or other legal reasons, including:
- When we reasonably believe disclosure is required to comply with a subpoena, court order, or other applicable law, regulation or legal process;
- To enforce, remedy, or apply our agreements and contractual rights;
- To protect our property (including intellectual property) or protect the rights, property or safety of others;
- To support external auditing, compliance and corporate governance functions; and
- To prevent, detect, and remedy fraud, cybersecurity attacks or illegal activity.
• With your Consent or Direction. We disclose personal data with your consent or at your direction, including if we notify you that your personal data will be shared in a particular manner and you provide such personal data.
HOW WE PROTECT YOUR PERSONAL DATA
We implement commercially reasonable physical, technical and procedural measures to help protect personal data from unauthorized access or use; however, the transmission of information via the internet is not completely secure or private. If you have questions about the security of personal data we collect, please contact us using the information provided below.
COOKIES AND OTHER INFORMATION COLLECTION TOOLS
What are cookies? A cookie is a small file containing a string of characters that is sent to your computer when you visit a website or use an online service. When you visit the website or use the online service again, the cookie allows that website or online service to recognize your browser or device. Cookies may store unique identifiers, user preferences and other information.
The type of cookies we may use include:
Necessary Cookies. These cookies are strictly necessary to make our Services function properly. These cookies ensure basic functionalities and security features of the Sites.
Functional Cookies. Functional cookies help to perform certain functionalities like sharing the content of the Sites on social media platforms, collect feedback, and other third-party features.
Performance Cookies. Performance cookies are used to understand and analyze the key performance indexes of the Sites which helps in delivering a better user experience for the visitors.
Analytics Cookies. Analytical cookies are used to understand how visitors interact with the Sites. These cookies help provide information on metrics, the number of visitors, bounce rate, traffic source, etc.
Advertisement Cookies. Advertisement cookies are used to provide visitors with relevant ads and marketing campaigns. These cookies track visitors across websites and collect information to provide customized ads.
Duration of Cookies. We may use "session cookies" or "persistent cookies." Session cookies are temporary and expire once you close your browser or once your session ends. Persistent cookies remain on your device for much longer or until you or your browser erases them. Persistent cookies have varying durations that are dependent on their expiration date.
Why do we use them? We and our business partners use cookies to collect information about you so we can provide the experiences you request, recognize your visit, track your interactions, improve your experience and detect and prevent fraud. We may use cookies provided by third-party partners such as analytics providers, customer relationship management platforms, or payment processors.
How do I control cookies? You can limit online tracking by:
• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
Do Not Track. Some Internet browsers can be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit allaboutdnt.com.
Where required by applicable law, we obtain your consent prior to placing or using optional cookies that are not (i) strictly necessary to provide the Site or the Services e.g., Necessary Cookies; or (ii) for the purpose of facilitating a communication.
Analytics Cookies. We currently use PostHog to provide us with analytics data relating to how you use our Services and provide marketing and advertising to you. You can learn more about how PostHog processes your personal data by visiting https://posthog.com/privacy. To manage or opt out of analytics tracking, you can adjust your browser settings to block or delete cookies, or use third-party tools that control cookie tracking.
SOCIAL MEDIA AND OTHER THIRD-PARTY LINKS AND SERVICES
Third Party Partners
Occasionally, at our discretion, we may include or offer third party products or services on our Sites or links to other websites including by connecting you with, or recommending the services of, our Network Providers. We also currently use Docusign for electronic signature processing and Stripe for identity verification and payment processing. In the future, we may engage additional partners to provide these or similar services. The privacy practices of these third parties will be governed by the parties' own privacy notices. We are not responsible for the security or privacy of any information collected by these third parties, except in the event such parties disclose such information to us, in which case this Policy will apply. You should review the privacy notices or policies applicable to these third-party products and/or services. We have no responsibility or liability for the content and activities of these linked websites or the services they provide.
Social Media
Some aspects of the Sites may allow you to interface with social media services such as Facebook, Instagram, LinkedIn, and X (formerly known as Twitter®). By using these interfaces, you will allow us to access information about you from those social media services, including information and other content that you submit to those social media services. For a description on how such social media services and other third-party platforms, plug-ins, integrations, and applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings with that service or platform.
Use of AI Services.
Our Services use artificial intelligence (AI) services (provided by third-party vendors), including to assist Users with general inquiries and navigation and to draft content for Users to display in our Services. When you interact with our AI chat features, you acknowledge that you are communicating with artificial intelligence and (i) your messages may be processed by third-party AI providers (such as Google or OpenAI) and (ii) we will process any of your personal data shared in chat according to this Policy, but the third-party AI provider will process your personal data in accordance with their own privacy policies and we are not liable for their handling of your personal data.
RETENTION OF PERSONAL DATA
We will retain your personal data for as long as is necessary to fulfil the purpose for which this data was collected and for the business purposes explained in this Policy.
Even after we stop providing Services directly to you, and even if you close your account, we may retain your personal data to the extent permitted by applicable law:
• to comply with our legal and regulatory obligations;
• to protect against fraudulent or abusive activity on our Service; or
• to exercise, establish or defend legal claims.
In cases where we keep personal data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law. Our retention periods will vary depending on the type of data involved, but generally, to determine the appropriate retention period for personal data, we consider:
• the amount, nature, and sensitivity of the personal data;
• the potential risk of harm from unauthorized use or disclosure of your personal data;
• whether such information is needed to provide services;
• whether there is a contractual or legal need to retain the data;
• the purposes for which we process your personal data and whether we can achieve such purposes through other means; and
• applicable legal requirements.
YOUR PRIVACY RIGHTS AND CHOICES
You may opt out of receiving direct marketing communications from us by following the unsubscribe instructions in those communications, visiting our unsubscribe page, or by contacting us as set forth below.
If you contact us to exercise the opt-out of direct marketing right, please note that we may only implement requests with respect to the personal data associated with you as an individual. We may need to verify your identity before implementing your request and will try to comply with your request as soon as reasonably practicable and in accordance with the timelines required under applicable law. If we cannot verify your identity or your ownership rights to the data, we may not be able to service your request until you provide proper documentation.
Please note that there are certain communications we are required to send you that relate to the Services we are providing to you or the organization you represent that you may not be able to opt out of (e.g., support and important legal notices).
CHILDREN'S PRIVACY
Our Services are not aimed at children under the age of 18 or the age defined under applicable law. We do not intentionally collect information from children under the age of 18 or the age defined under applicable law.
CONTACT US
If you have any questions about this Policy or feedback about our Services, you may contact us at privacy@cuentra.co.