ASPENWAY REALTY PRIVACY POLICY

1) WHO WE ARE AND HOW TO CONTACT US

AspenWay Realty

Address: 825 Town & Country Ln, #1200, Houston, TX 77024

Phone: 713.331.1954

Email: info@aspenwayrealty.com

2) SCOPE

This Policy applies to:

• Site visitors
• Individuals who submit forms, request information, schedule showings, or otherwise contact us
• Prospective clients, clients, and business contacts

This Policy does not apply to third-party websites or services you may access through links on the Site.

3) INFORMATION WE COLLECT

We collect personal information in three ways.

A) Information you provide

• Identifiers and contact details (name, email, phone, mailing address)
• Inquiry content (messages, preferences, timeline, budget range, property interests)
• Appointment details (showing requests and scheduling information)
• Communications (emails, texts, call content or call recordings where permitted by law)
• Marketing preferences and consent choices
• Client and transaction information (only if you engage us), which may include identity verification information and other details necessary to provide services, satisfy legal obligations, or coordinate a transaction

B) Information collected automatically

• Device and network data (IP address, browser type, device type, operating system, language settings)
• Approximate location (city/state derived from IP address)
• Usage data (pages viewed, time on page, navigation paths, clicks, referral URLs)
• Cookie and similar technology data (cookies, pixels, local storage, SDKs)

C) Information from third parties

• Social media platforms if you interact with our pages or content
• Advertising, analytics, and attribution providers
• Real estate listing and property data sources (including IDX/MLS vendors and related providers) when you use listing features
• Public sources (such as property records) where permitted by law

4) COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies for:

• Core site functionality
• Security and fraud prevention
• Analytics and performance
• Marketing and advertising (where enabled)

Your controls:

• Browser controls to block or delete cookies
• Device settings to limit advertising identifiers (mobile)
• If available, our cookie banner or preference center for optional cookies where required by law

Do Not Track:

Some browsers send "Do Not Track" signals. The Site may not respond to these signals.

5) HOW WE USE PERSONAL INFORMATION

We use personal information to:

• Provide and operate the Site and real estate services
• Respond to inquiries, schedule showings, and communicate with you
• Provide customer support and manage our relationship with you
• Send administrative and service messages (including security notices)
• Improve the Site, troubleshoot issues, and perform analytics
• Personalize content and maintain the quality of user experience
• Market our services consistent with your choices and applicable law
• Prevent fraud, abuse, unauthorized access, and security incidents
• Comply with law, enforce our terms, and protect rights and safety

6) HOW WE DISCLOSE PERSONAL INFORMATION

We do not sell personal information for money.

We may disclose personal information as follows.

A) Service providers (processors)

We share information with vendors that perform services for us, such as:

• Hosting, content delivery, and site operations
• CRM and communications tools
• Appointment scheduling and support tools
• Analytics and measurement providers
• Security monitoring and fraud prevention vendors

They may use personal information only to provide services to us, subject to contractual protections.

B) Real estate transaction partners (when you engage us)

As needed to deliver services or complete a transaction, we may share information with:

• Lenders or mortgage brokers you choose or authorize
• Title, escrow, settlement, and closing providers
• Inspectors, appraisers, attorneys, and other professional service providers involved in your transaction
• Showing coordination and listing platforms
• MLS/IDX and listing data providers to deliver listing and search features you request

C) Legal, compliance, and safety

We may disclose information to comply with law or lawful requests, and to protect rights, safety, and security, including to investigate suspected fraud or security incidents.

D) Business transfers

If we undergo a business transaction (such as a merger or sale), personal information may be transferred subject to appropriate safeguards.

7) MARKETING, EMAIL, AND SMS TEXT MESSAGES

Email:

You can opt out of marketing emails using the unsubscribe link or by contacting us. Service-related messages may still be sent.

SMS:

If you opt in to receive text messages:

• Message frequency varies
• Message and data rates may apply
• You can opt out by replying STOP
• You can request help by replying HELP

No marketing disclosure of phone/SMS consent:

We do not disclose phone numbers or SMS opt-in consent to third parties for their own marketing purposes.

Calls and prerecorded messages:

Where required, we obtain consent before sending marketing texts or using automated dialing or prerecorded/artificial voice messages. Your consent is not required to purchase services.

8) DATA RETENTION

We retain personal information only as long as reasonably necessary for:

• The purposes described in this Policy
• Business records and operational needs
• Legal, regulatory, tax, and audit obligations
• Dispute resolution and enforcement

We may de-identify information and retain it in de-identified form where permitted by law.

9) SECURITY

We use reasonable administrative, technical, and physical safeguards designed to protect personal information. No system is perfectly secure. We cannot guarantee absolute security.

10) CHILDREN

The Site is not intended for children under 18. We do not knowingly collect personal information from children under 18.

11) THIRD-PARTY LINKS AND EMBEDDED FEATURES

The Site may include links or embedded tools operated by third parties (for example, maps, video, social media, analytics). Their privacy practices are governed by their own policies. We are not responsible for third-party practices.

12) YOUR PRIVACY RIGHTS (UNITED STATES)

Depending on where you live, you may have rights to:

• Access personal information we hold about you
• Correct inaccurate information
• Delete certain personal information
• Obtain a copy of your information (portability)
• Opt out of targeted advertising, sale of personal data, or certain profiling (where applicable)

How to exercise rights:

Contact us using the information in Section 1. We may verify your identity before fulfilling requests.

Authorized agents:

Where permitted by law, you may use an authorized agent. We may require proof of authorization and identity verification.

Appeals:

Where required, you may appeal a decision regarding your request by contacting us and stating you are appealing a privacy decision.

13) CALIFORNIA PRIVACY NOTICE (CCPA/CPRA)

If you are a California resident:

A) Categories of personal information we may collect

• Identifiers (name, email, phone, IP address)
• Personal records information (contact information and similar details)
• Internet/network activity (usage data, cookie data)
• Geolocation (approximate location derived from IP)
• Professional or employment-related information (if you provide it)
• Inferences (preferences derived from interactions, where applicable)

Sensitive personal information:

We do not seek sensitive personal information through standard Site forms. If you become a client, certain transaction-related information may be sensitive. We use it only as permitted by law for providing services, completing transactions, security, and compliance.

B) Purposes and disclosures

We use and disclose information as described in Sections 5 and 6.

C) Selling and sharing

We do not sell personal information for money.

We do not share personal information for cross-context behavioral advertising in a manner that is considered "sharing" under the CPRA, unless we clearly disclose it and provide required opt-out mechanisms.

D) California rights

You may have the right to request access, deletion, correction, information about disclosures, and to limit certain uses of sensitive personal information where applicable. You also have the right to non-discrimination for exercising rights.

14) TEXAS PRIVACY NOTICE (TDPSA)

If you are a Texas resident, you may have rights under the Texas Data Privacy and Security Act, including access, correction, deletion, portability, and opt out rights for targeted advertising, sale of personal data, and certain profiling. You may submit requests as described in Section 12.

15) INTERNATIONAL VISITORS

We operate in the United States. If you access the Site from outside the U.S., your information may be processed and stored in the United States or other jurisdictions where our service providers operate.

16) CHANGES TO THIS POLICY

We may update this Policy from time to time. Changes are effective when posted. The "Last Updated" date will be revised accordingly.