Privacy Policy

1. Who This Policy Covers

1.1 Users of the Platform

This Privacy Policy applies to all individuals who use the Platform directly, including licensed real estate agents, transaction coordinators, brokerage administrators, and any other authorized users who access the Platform under a CurbPage subscription (collectively, "Users"). If you are a User, CurbPage acts as a data controller with respect to your personal information—we determine the purposes and means of processing your information as described in this policy.

1.2 Clients of Agents

When an agent uses the Platform to manage a real estate transaction on behalf of a client, that client's personal information may be uploaded to or generated within the Platform. With respect to Client Data (defined in Section 3), CurbPage acts as a data processor on behalf of the agent. The agent is the data controller for Client Data and is responsible for their own privacy disclosures to clients. CurbPage processes Client Data only as directed by the agent and in accordance with this policy and the Terms of Service.

1.3 Website Visitors

This policy also applies to visitors to curbpage.com and any other CurbPage-operated websites, to the extent we collect information from those visits. Website visitors who are not Users or Clients are subject to the provisions of this policy that apply to automatically collected information and cookies (Sections 2.3 and 7).

2. Information CurbPage Collects About Agents and Users

2.1 Account and Profile Information

When you register for a CurbPage account, we collect information necessary to create and maintain your account, including:

• Full name

• Email address

• Phone number

• Real estate license number and licensing state

• Brokerage name and affiliation

• Job title or role (e.g., agent, transaction coordinator, brokerage administrator)

• Profile photo (if you choose to upload one)

• Business address

• Time zone and communication preferences

2.2 Subscription and Billing Information

When you subscribe to the Platform, billing information is collected and processed by our payment processor, Stripe, Inc. CurbPage does not directly store full credit card numbers or bank account details. The billing information CurbPage retains includes:

• Subscription plan and billing cycle

• Billing address

• Transaction records (dates, amounts, plan history)

• Partial payment method identifiers (e.g., last four digits of a card, card type) as provided by Stripe for reference purposes

For more detail on payment data processing, please see the CurbPage Payments Terms of Service at curbpage.com/payments-terms.

2.3 Information Collected Automatically

When you use the Platform or visit our website, we automatically collect certain technical and usage information, including:

• Log Data: IP address, browser type and version, operating system, referring URLs, pages visited, time and date of visits, and session duration.

• Device Information: Device type, hardware model, unique device identifiers, and mobile network information.

• Usage Data: Features used, actions taken within the Platform, transaction records created or modified, search queries, and interactions with Platform tools.

• Performance Data: Crash reports, error logs, and performance metrics used to diagnose and improve the Platform.

• Cookies and Similar Technologies: As described in Section 7 of this policy.

2.4 Communications with CurbPage

When you contact CurbPage's support team, respond to surveys, participate in research, provide feedback, or otherwise communicate with us, we collect the content of those communications and any information you choose to include. Support communications may be retained for quality assurance, training, and product improvement purposes.

2.5 Information from Third Parties

We may receive information about you from third parties in limited circumstances, including:

• Brokerage Administrators: A brokerage administrator may provide your name, email address, and role when provisioning your account as part of a brokerage-level subscription.

• Referrals: If another User refers you to CurbPage, we may receive your name and email address for the purpose of sending you an invitation.

• Integration Partners: If you connect a third-party application to your CurbPage account (see Section 8), we may receive information from that application as authorized by you.

• Publicly Available Sources: In limited cases, we may verify professional information (such as licensure status) using publicly available sources such as state real estate commission databases.

3. Client Data: A Special Category

3.1 What Is Client Data

"Client Data" means any personal information relating to an agent's clients—homebuyers, sellers, or other individuals whose real estate transactions are managed through the Platform—that is uploaded, entered, generated, or stored on the Platform by a User. Client Data may include:

• Client names, email addresses, and phone numbers

• Property addresses and transaction details

• Transaction timelines, milestones, and status updates

• Documents uploaded in connection with a transaction (e.g., contracts, disclosures, inspection reports)

• Messages and communications between the agent and client through the Platform

• Vendor and third-party contact information associated with a transaction

• Any other information the agent enters about a client or transaction

3.2 CurbPage as Data Processor for Client Data

With respect to Client Data, CurbPage acts solely as a data processor. The agent who uploads or enters Client Data is the data controller responsible for that data. CurbPage processes Client Data only to provide and operate the Platform and only in accordance with the agent's instructions (as expressed through their use of the Platform) and these terms.

This means:

• CurbPage does not use Client Data for CurbPage's own marketing or advertising purposes.

• CurbPage does not sell or rent Client Data to any third party.

• CurbPage does not analyze or mine Client Data for purposes unrelated to providing the Platform to the agent.

• CurbPage will only share Client Data with third parties as described in Section 6 of this policy.

3.3 Agent Responsibility for Client Data

Agents are solely responsible for:

• Obtaining any necessary consent or authorization from clients before uploading their personal information to the Platform;

• Providing clients with appropriate notice about how their information will be handled in connection with the Platform;

• Ensuring that their collection and use of Client Data complies with all applicable privacy laws, including state privacy laws in their jurisdiction; and

• Responding to any privacy rights requests from clients regarding their personal information, including requests to access, correct, or delete Client Data.

CurbPage will cooperate with agents in responding to legitimate Client privacy rights requests to the extent technically feasible. Agents should contact support@curbpage.com for assistance with Client Data requests.

3.4 Aggregated and Anonymized Client Data

CurbPage may create aggregated, de-identified, and anonymized datasets derived from Client Data that do not identify any individual client or agent. CurbPage may use such aggregated data for product analytics, industry benchmarking, and other lawful business purposes. No individual client or agent will be identifiable from such aggregated data.

4. How CurbPage Uses Agent and User Information

CurbPage uses the personal information of agents and other Users for the following purposes:

4.1 To Provide and Operate the Platform

• Creating and managing your account

• Processing subscription payments and managing billing

• Providing access to Platform features and services

• Sending transactional communications (account confirmations, receipts, password resets, security alerts)

• Enabling you to use collaboration, communication, and transaction management features

• Provisioning and managing access for brokerage accounts and team members

4.2 To Support and Improve the Platform

• Diagnosing technical problems and resolving bugs

• Analyzing usage patterns to improve Platform features and user experience

• Developing new features, tools, and integrations

• Conducting user research and gathering feedback

• Providing customer support and training

• Generating anonymized and aggregated analytics about Platform usage

4.3 For Safety, Security, and Compliance

• Detecting and preventing fraud, unauthorized access, and security threats

• Verifying user identity and professional credentials

• Enforcing the Terms of Service, this Privacy Policy, and other applicable policies

• Complying with applicable laws, regulations, and legal obligations

• Responding to lawful requests from government authorities and courts

• Protecting the rights, property, and safety of CurbPage, Users, and third parties

4.4 For Marketing and Business Communications

• Sending product updates, newsletters, and information about new features (with the ability to opt out as described in Section 14)

• Notifying you of changes to the Platform, pricing, or these policies

• Providing information about other CurbPage products or services that may be of interest to you

• Conducting satisfaction surveys and research

CurbPage will not sell or rent your personal information to third parties for their own marketing purposes.

4.5 Legal Bases for Processing (Where Applicable)

Where applicable law requires a legal basis for processing personal information, CurbPage relies on the following bases:

• Contract Performance: Processing necessary to provide the Platform in accordance with the Terms of Service (e.g., account management, billing, customer support).

• Legitimate Interests: Processing necessary for CurbPage's legitimate business interests, including security, fraud prevention, product improvement, and marketing, where those interests are not overridden by your privacy rights.

• Legal Obligation: Processing necessary to comply with applicable laws and regulations.

• Consent: Where required by law, CurbPage will request your consent before processing your information for specific purposes such as marketing communications or the use of non-essential cookies.

5. How CurbPage Uses Client Data

As a data processor for Client Data, CurbPage uses Client Data strictly for the following purposes:

• Storing and displaying Client Data within the Platform as directed by the agent;

• Enabling the Platform's transaction management, task tracking, client portal, and communications features to function as intended;

• Facilitating any agent-authorized communications between the Platform and the client's email address (e.g., client portal invitations, document notifications);

• Creating backups and ensuring data durability and availability;

• Generating aggregated, anonymized data as described in Section 3.4; and

• Complying with legal obligations, including responding to lawful legal process as described in Section 6.3.

CurbPage will not use Client Data for its own marketing, advertising, product development, or any purpose other than providing the Platform to the agent, except to create anonymized and aggregated data as described above.

6. How CurbPage Shares Information

6.1 Service Providers

CurbPage shares User information and Client Data with trusted third-party service providers who assist us in operating the Platform. These providers are contractually required to use information only for the purposes for which it was shared and to implement appropriate security measures. Current categories of service providers include:

Service Category

Purpose

Cloud Infrastructure

Hosting the Platform, storing data, and ensuring availability and reliability

Payment Processing

Processing subscription payments and managing billing (Stripe, Inc.)

Customer Support

Providing in-app support and managing support communications (Intercom)

Product Analytics

Understanding how the Platform is used to improve features and performance (PostHog)

Email & Communications

Sending transactional and marketing email communications

Call Recording & Analysis

Recording and transcribing sales and support calls for quality and training (Fathom)

CRM & Sales Operations

Managing sales pipeline and customer relationships (Attio)

Error Monitoring

Detecting and diagnosing technical errors in the Platform

CurbPage does not authorize service providers to use your information for their own independent purposes. CurbPage maintains data processing agreements with service providers who handle personal data on our behalf.

6.2 Business Transfers

If CurbPage undergoes a merger, acquisition, reorganization, bankruptcy, dissolution, or sale of all or substantially all of its assets, your personal information and Client Data may be transferred to the acquiring entity as part of that transaction. CurbPage will provide notice of any such transfer and the new entity will be bound by the terms of this Privacy Policy or will notify you of any changes to the applicable privacy terms before such changes take effect.

6.3 Legal Requirements and Protection of Rights

CurbPage may disclose personal information and Client Data when we believe in good faith that disclosure is necessary to:

• Comply with applicable law, regulation, or a valid legal process (including subpoenas, court orders, or government requests);

• Enforce the Terms of Service or other agreements;

• Detect, prevent, or address fraud, security threats, or technical issues;

• Protect the rights, property, or safety of CurbPage, its Users, Clients, or the public; or

• Respond to an emergency that poses a risk to the life or safety of any person.

Where legally permitted, CurbPage will notify affected Users of legal process before complying, unless prohibited from doing so by the terms of the legal process or applicable law.

6.4 Brokerage Account Administrators

If you access the Platform as part of a brokerage account, your account administrator has visibility into certain aspects of your account, including the transactions you have created, your overall activity on the Platform, and your account status. Brokerage administrators do not have access to the content of your private communications with CurbPage support.

6.5 With Your Consent

CurbPage may share your information with other third parties where you have provided explicit consent for such sharing. You may withdraw such consent at any time, though withdrawal will not affect the lawfulness of sharing that occurred before consent was withdrawn.

6.6 No Sale of Personal Information

CurbPage does not sell, rent, or trade personal information or Client Data to third parties for their own marketing, advertising, or commercial purposes. This applies to both agent/user personal information and to Client Data.

7. Cookies and Tracking Technologies

7.1 What We Use

CurbPage uses cookies and similar tracking technologies (collectively, "Cookies") on our website and within the Platform. Cookies are small text files placed on your device that help us recognize you, remember your preferences, and understand how you use our services.

We use the following categories of Cookies:

• Strictly Necessary Cookies: Essential for the Platform to function. These include cookies that authenticate your session, maintain your login state, and enable core security features. These cannot be disabled without disrupting the Platform.

• Functional Cookies: Enable enhanced functionality and personalization, such as remembering your language preference, layout settings, and other user-specific configurations.

• Analytics Cookies: Help us understand how Users interact with the Platform, which features are most used, and where technical issues occur. We use this information to improve the Platform. Analytics data is collected in aggregate and is not used to identify individual users for marketing purposes.

• Marketing Cookies: Used on our public-facing website to understand the effectiveness of our marketing activities. We do not use marketing cookies within the authenticated Platform application.

7.2 Managing Cookies

You can manage Cookie preferences through:

• Your browser settings, which allow you to block or delete cookies. Note that blocking strictly necessary cookies may impair Platform functionality.

• Our cookie preference center, available via the cookie banner displayed when you first visit curbpage.com.

• Opting out of analytics tracking as described in your account privacy settings.

Please note that some third-party cookies are placed by our service providers (such as analytics tools) and are subject to those providers' privacy policies.

7.3 Do Not Track

Some browsers include a Do Not Track (DNT) signal. CurbPage does not currently alter its data collection or use practices in response to DNT signals because there is no universally accepted standard for how DNT should be interpreted. We will reassess this position as industry standards develop.

8. Third-Party Integrations

8.1 User-Authorized Integrations

CurbPage may offer integrations with third-party services and applications, including calendar applications, e-signature platforms, MLS data providers, and document storage services. When you connect a third-party integration to your CurbPage account, you authorize CurbPage to exchange information with that service as necessary to enable the integration.

8.2 Third-Party Privacy Practices

Each integrated third-party service has its own privacy policy and data practices. CurbPage is not responsible for the privacy practices of third-party services. Before enabling any integration, we encourage you to review the privacy policy of the relevant third-party service. By enabling an integration, you acknowledge that your data may be shared with and processed by that third-party service.

8.3 Revoking Integration Access

You may revoke third-party integration access at any time through your account settings or by contacting support@curbpage.com. Revoking integration access will stop future data sharing with the third party, but will not delete data that has already been shared.

8.4 Third-Party Links

The Platform or CurbPage website may contain links to third-party websites. These links are provided for your convenience and do not constitute an endorsement of those websites. CurbPage is not responsible for the content or privacy practices of any linked third-party websites.

9. Data Retention

9.1 Active Account Retention

CurbPage retains personal information and Client Data for as long as your account is active and for a reasonable period thereafter to fulfill the purposes described in this policy, comply with legal obligations, resolve disputes, and enforce agreements.

9.2 Following Account Cancellation

When your subscription is cancelled or terminated:

• Your account data and Client Data will remain accessible for a 30-day grace period during which you can export your data using the Platform's export tools.

• Following the 30-day grace period, CurbPage may permanently delete your account and all associated data.

• CurbPage will retain certain information for longer periods where required by law (e.g., billing records for tax purposes) or to enforce legal rights (e.g., records of Terms of Service violations).

9.3 Billing Records

CurbPage retains billing and transaction records for a minimum of seven (7) years from the date of the transaction, in accordance with standard financial record-keeping requirements.

9.4 Communications

Support communications and call recordings are retained for up to two (2) years for quality assurance and training purposes, unless a longer retention period is required by applicable law.

9.5 Anonymized Data

Aggregated, anonymized data that does not identify any individual may be retained indefinitely for analytical and business purposes.

9.6 Deletion Requests

Users may request deletion of their personal information as described in Section 12. CurbPage will honor deletion requests subject to any legal obligations to retain certain records. Deletion requests for Client Data should be directed to the agent who controls that data; agents may contact support@curbpage.com for assistance with Client Data deletion.

10. Security

10.1 Security Measures

CurbPage implements commercially reasonable technical, organizational, and administrative security measures designed to protect personal information and Client Data against unauthorized access, disclosure, alteration, destruction, or loss. These measures include:

• Encryption of data in transit using TLS (Transport Layer Security);

• Encryption of sensitive data at rest;

• Access controls and authentication requirements for Platform access;

• Regular security assessments and vulnerability management;

• Employee security training and access management policies; and

• Data processing agreements with service providers who handle personal data.

10.2 No Absolute Guarantee

Despite our security measures, no method of data transmission or storage is completely secure. CurbPage cannot guarantee the absolute security of personal information or Client Data. In the event of a security breach that is likely to affect your rights, CurbPage will notify you in accordance with applicable law.

10.3 Your Responsibilities

You are responsible for maintaining the security of your account credentials. Do not share your password with others. If you believe your account has been compromised, contact us immediately at support@curbpage.com.

10.4 Security Incidents

If CurbPage discovers a security incident that affects personal information, we will investigate promptly, take appropriate remediation steps, and notify affected individuals and relevant authorities as required by applicable law. CurbPage will provide timely and transparent communication about any breach that is likely to affect your rights or interests.

11. Children's Privacy

The Platform is intended for use by adults who are licensed real estate professionals or who are authorized to act on behalf of a licensed real estate brokerage. The Platform is not directed to children under the age of 13, and CurbPage does not knowingly collect personal information from children under 13.

If you are a parent or guardian and believe that CurbPage has collected personal information from a child under 13 without appropriate consent, please contact us at hello@curbpage.com, and we will take prompt steps to delete such information.

Client Data may sometimes include information about minors in the context of family real estate transactions (e.g., as members of a household). Agents are responsible for ensuring that any such information is collected and handled lawfully and with appropriate consent.

12. Your Privacy Rights

12.1 Rights of Users

Depending on where you are located, you may have the following rights with respect to your personal information:

• Right to Access: The right to request confirmation of whether CurbPage processes your personal information and, if so, to receive a copy of the information we hold about you.

• Right to Correction: The right to request that we correct inaccurate or incomplete personal information. You can also update most account information directly through your account settings.

• Right to Deletion: The right to request that we delete your personal information, subject to legal obligations requiring retention.

• Right to Data Portability: The right to receive a copy of your personal information in a structured, commonly used, and machine-readable format, where technically feasible.

• Right to Restrict Processing: The right to request that we limit how we use your personal information in certain circumstances.

• Right to Object: The right to object to certain processing of your personal information, including processing for direct marketing purposes.

• Right to Withdraw Consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of processing before withdrawal.

12.2 How to Exercise Your Rights

To exercise any of the rights listed above, please contact us at:

Email: hello@curbpage.com

Subject: "Privacy Rights Request"

Please include your full name, email address associated with your account, and a description of the right you wish to exercise. CurbPage will respond to your request within 30 days (or within the timeframe required by applicable law). We may need to verify your identity before fulfilling your request.

12.3 Rights Are Not Absolute

Some of the rights described above are not absolute and may be subject to exceptions under applicable law. For example, CurbPage may retain information as required to comply with legal obligations, enforce agreements, or exercise legal claims, even if you have requested deletion.

12.4 Client Privacy Rights

Clients whose data has been uploaded to the Platform by an agent should contact that agent directly to exercise their privacy rights. CurbPage will cooperate with agents in responding to legitimate Client privacy rights requests. If a Client cannot reach the agent, they may contact CurbPage at hello@curbpage.com, and we will make reasonable efforts to assist within our capacity as a data processor.

13. California Privacy Rights (CCPA / CPRA)

13.1 Applicability

This section applies to California residents whose personal information is processed by CurbPage in a business context covered by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, "CCPA/CPRA").

13.2 Categories of Personal Information Collected

In the preceding 12 months, CurbPage has collected the following categories of personal information from California residents who are Users of the Platform:

• Identifiers (name, email address, IP address, device identifiers)

• Professional or employment-related information (real estate license number, brokerage affiliation)

• Commercial information (subscription and billing records)

• Internet or other electronic network activity information (usage data, log data)

• Geolocation data (approximate location derived from IP address)

• Audio, electronic, visual, or similar information (support call recordings, where applicable and with notice)

• Inferences drawn from the above to create a profile about a user (product usage patterns)

13.3 Purposes for Collection

CurbPage collects the above categories of personal information for the business purposes described in Section 4 of this policy.

13.4 No Sale or Sharing of Personal Information

CurbPage does not sell personal information as defined under CCPA/CPRA, and does not share personal information for cross-context behavioral advertising purposes. CurbPage has not sold or shared personal information in the preceding 12 months.

13.5 California Privacy Rights

California residents have the following rights under CCPA/CPRA:

• The right to know what personal information CurbPage has collected, used, disclosed, and shared;

• The right to delete personal information, subject to certain exceptions;

• The right to correct inaccurate personal information;

• The right to opt out of the sale or sharing of personal information (though CurbPage does not sell or share personal information as described above);

• The right to limit the use and disclosure of sensitive personal information; and

• The right to non-discrimination for exercising any CCPA/CPRA rights.

13.6 How to Submit a California Privacy Request

California residents may submit privacy rights requests by contacting us at hello@curbpage.com with the subject line "California Privacy Request." CurbPage will respond within 45 days, with a possible 45-day extension where reasonably necessary. CurbPage will not discriminate against you for exercising your California privacy rights.

13.7 Authorized Agent

California residents may designate an authorized agent to submit privacy requests on their behalf. To use an authorized agent, please provide written authorization signed by you or a power of attorney, along with the agent's contact information, in your request.

14. Communications Preferences

14.1 Transactional Communications

CurbPage will send you transactional communications that are necessary for the operation of your account and the Platform, including subscription confirmations, receipts, security alerts, password reset emails, and policy update notices. You cannot opt out of transactional communications while you maintain an active account.

14.2 Marketing Communications

With your consent (express or implied, as permitted by applicable law), CurbPage may send you marketing communications, including product news, feature announcements, tips for using the Platform, and information about CurbPage's products and services. You may opt out of marketing communications at any time by:

• Clicking the "Unsubscribe" link included in any marketing email; or

• Updating your communication preferences in your account settings; or

• Contacting us at support@curbpage.com with your opt-out request.

Opt-out requests will be processed within 10 business days. After opting out of marketing communications, you will continue to receive transactional communications.

14.3 In-App Notifications

The Platform may send you in-app notifications about account activity, transaction updates, and platform changes. You can manage in-app notification preferences through your account settings. Some critical security notifications cannot be disabled.

15. Changes to This Privacy Policy

CurbPage may update this Privacy Policy from time to time. When we make material changes, we will:

• Post the updated policy at curbpage.com/privacy;

• Update the "Last Updated" date at the top of the policy;

• Notify you via email and/or in-Platform notification at least 14 days before material changes take effect.

Your continued use of the Platform after the effective date of any update constitutes your acceptance of the revised policy. If you do not agree to the updated policy, you must stop using the Platform before the effective date.

For changes that materially affect how we process Client Data, CurbPage will provide notice to agents in sufficient time for agents to update their own privacy disclosures to their clients, where required by applicable law.

16. Contact Us

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

CurbPage, Inc.

Email (privacy):   hello@curbpage.com

Email (support):   support@curbpage.com

Website:           curbpage.com

For Client Data requests or data processing inquiries, please use the subject line "Data Privacy Inquiry" in your email. CurbPage will respond to all privacy inquiries within 30 days.

17. Definitions

For purposes of this Privacy Policy, the following terms have the meanings set forth below:

• "Agent" or "User" means any individual who accesses or uses the Platform under a registered CurbPage account, including licensed real estate agents, transaction coordinators, and brokerage administrators.

• "Client" means a homebuyer, home seller, or other individual whose real estate transaction is managed through the Platform by an Agent. Clients are not direct users of the Platform in its agent-facing capacity, though they may access a read-only client portal.

• "Client Data" means personal information relating to a Client that is uploaded, entered, generated, or stored on the Platform by an Agent.

• "CurbPage," "we," "us," or "our" means CurbPage, Inc., a Delaware corporation.

• "Data Controller" means the party that determines the purposes and means of processing personal information. CurbPage is a data controller with respect to Agent and User personal information.

• "Data Processor" means the party that processes personal information on behalf of and at the direction of a data controller. CurbPage is a data processor with respect to Client Data.

• "Personal Information" means any information that identifies or could reasonably be used to identify an individual, directly or indirectly.

• "Platform" means the CurbPage web application, mobile applications, APIs, and all related services.

• "Terms of Service" means the CurbPage Terms of Service available at curbpage.com/terms.