Privacy Policy

PRIVACY POLICY FOR INDIVIDUALS INTERACTING WITH RIGHTLY REALTY

Last Updated: October 27, 2024

Introduction

Rightly Realty, a DBA for Zero Realty, Inc. (“Rightly”, “we”, “us”, or “our”) provides real estate services (collectively, “Services”) used by our real estate agents and clients (the “Client”).

If you are a visitor to our Client website or portal (together the “Site”), this Privacy Policy applies to you, and describes Rightly's policies and practices regarding the collection, use and disclosure of your personal information in connection with your use of the Site and our provision of the Services to our Client.

  • Personal Information We Collect
    • Rightly does not sell your personal information, but we may share your personal information, as defined by applicable privacy laws, which may result in third parties receiving your personal information. You (or your legally authorized agent) can opt out of the sharing of your personal information by sending an email to us at [email protected].
    • Information you provide to us. Personal information you provide to us through the Services may include:
      • Contact information that you provide, such as your first and last name, email address, and phone number.
      • Feedback or correspondence, such as information you provide when you contact us in connection with the Site or Services with questions, feedback, or otherwise correspond.
      • Marketing information, such as your preferences for receiving communications, events, and publications, and details about how you engage with such communications.
      • Other information which is not specifically listed here that you may provide voluntarily or that is necessary in connection with your interactions with the us through the Site or Services. All such information will be used in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.
    • Information we obtain from third parties:
      • Social media information. We may maintain pages on social media platforms, such as Realto.com, Zillow, Homes.com, the MLS, Facebook, LinkedIn, Instagram, and other third-party platforms. When you visit or interact with these pages on those platforms, the platform providers’ privacy policies will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us (on behalf of the Client) with information through the platform, and we will treat such information in accordance with this Privacy Policy.
      • Other Sources. We may obtain your personal information from other third parties, such as third party analytics services, our marketing partners, publicly-available sources and data providers.
    • Automatic data collection. Advertising partners, and our service providers may view information about you, your computer or mobile device, and your interaction over time with our Services, our communications and other online services, such as:
      • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 4G), and general location information such as city, state or geographic area.
      • Online activity data, such as the status of your home selling or buying processs with us, pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.
    • We use the following tools for automatic data collection:
      • Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
      • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
      • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
  • How We Use Your Personal Information
    • To operate our Services:
      • Provide free-to-use real estate agents to our clients
      • Provide, operate, and improve our Services and our business;
      • Communicate with you about our Services, including by sending announcements, SMS, emails, updates, security alerts, support and administrative messages;
      • Provide support, and respond to requests, questions, and feedback.
    • To comply with law. As we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
    • Marketing. If you have provided us with your contact or other information about your home sale or purchase, our partners may from time-to-time send you direct marketing communications as permitted by law, including through phone, email and text messages. If you would like to opt-out from marketing communications, please contact us before using our services.
    • For compliance, fraud prevention, and safety. To: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern our Services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
  • How We Share Your Personal Information
    • Vendors or Third Parties. We do not sell any of our Client's personal information (as defined under applicable laws) but we may share your personal information as described below and as described elsewhere in this Privacy Policy.
    • Our service providers. Companies and individuals that provide services on our behalf or help us operate our services or our business.
    • Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us to complete a home sale or purchase.
    • For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.
    • Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.
  • Privacy Choices
    • You have the following choices regarding our collection and use of your personal information:
      Online tracking opt-out. There are a number of ways to opt out of having your online activity and device data collected through our Services, which we have summarized below:
      • 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 allaboutcookies.org.
      • Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
      • Using privacy plug-ins or browsers. You can block our Services from setting cookies used for third party analytics or interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser-plug in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
      • Platform opt-outs. The following advertising partners offer opt-out features that let you opt out of use of your information for interest-based advertising:
      • Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
    • Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.
      Privacy rights. You have the right to submit requests about your personal information, depending on your location and the nature of your interactions with the Site and our Services:
      • Information about how we have collected and used your personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
      • Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
      • Correction of personal information that is inaccurate or out of date.
      • Deletion of personal information that we no longer need to provide our services or for other lawful purposes.
      • Additional rights, such as to object to and request that we restrict our use of your personal information, and where applicable, you may withdraw your consent.
    • If you wish to exercise your rights, please contact the corresponding Client as we process your personal information solely as a service provider and data processor on behalf of such Client.
    • Do Not Track. Some Internet browsers may 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 http://www.allaboutdnt.com.
  • Third Party Services
    • The Site and Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.
  • Security
    • We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of personal information.
  • Children
    • Our Services are not intended for use by children under 18 years of age. If we learn that we have collected personal information through the Services from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.
  • Changes to this Privacy Policy
    • We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on this website.
  • How to Contact Us
    • You can reach us by email using the "Conact" link in the main menu header of the website or at the following mailing address:

      Rightly Realty
      350 10th Avenue
      #1000
      San Diego, CA 92037

  • California Privacy Notice
    • Notice at Collection and California Privacy Policy
      Rightly Realty respects your privacy and we are committed to providing you with transparency as to our collection, use, disclosure, sale, sharing, and retention of personal information (“Information Practices”), and how you are able to manage your privacy choices. This California Notice at Collection and Privacy Policy (“CA Privacy Notice”) applies solely to California residents. The CA Privacy Notice does not apply to information we collect in the context of an individual’s interaction with us as a job applicant, employee, contractor, or other role within Rightly.
    • Notice at Collection
      The following notice identifies the categories of personal information to be collected from you and the purposes for which the personal information will be used, including whether that information is sold or shared.
    • General Personal Information

      A. We collect identifying information. For example: a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, agent license number and licensing state; date of birth; debit card information; credit card information; IP address; Cookie Session Identifier; or other similar identifiers. The purpose for collection is: 1) To fulfill or meet the reason for which the information is provided. 2) Servicing transactions and accounts (e.g.customer verification). 3) Undertaking internal research for technological development and demonstration. 4) To share the personal information with service providers to carry out other business purposes. For 1-4, this information is not sold to third parties.

      B. We collect personal Information Categories from Cal. Civ. Code § 1798.80(e). For example, a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. The purpose for this collection: 1) To fulfill or meet the reason for which the information is provided. 2) Servicing transactions and accounts (e.g.customer verification). 3) Undertaking internal research for technological development and demonstration. 4) To share the personal information with service providers to carry out other business purposes. For 1-4, this information is not sold to third parties.

      C. We collect characteristics of CA or Federal Protected Classifications. For example, race, religion, national origin), age (40 and over), gender, sexual orientation, medical condition, pregnancy (includes childbirth, breastfeeding and/or related medical conditions), familial status, disability, veteran status, or genetic information. The purpose for this collection is short-term data use for the current interaction that is not used to build a profile. This information is not sold to third-parties.

      D. We collect commercial Information. For example, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. The purpose for this collection is: The purpose for this collection: 1) To fulfill or meet the reason for which the information is provided. 2) Servicing transactions and accounts (e.g.customer verification). 3) Undertaking internal research for technological development and demonstration. 4) To share the personal information with service providers to carry out other business purposes. For 1-4, this information is not sold to third parties.

      E. We collect biometric Information. For example, photos indicating a physical likeness, and keystroke patterns. The purpose for this collection is: The purpose for this collection: 1) To fulfill or meet the reason for which the information is provided. 2) For our internal operation purposes. 3) Debugging to identify and repair errors. 4) Undertaking internal research for technological development and demonstration. For 1-4, this information is not sold to third parties.

      F. We collect internet or Other Similar Network Activity. For example, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement, or Zoom data for employees. The purpose for this collection is: The purpose for this collection: 1) To fulfill or meet the reason for which the information is provided. 2) For our internal operation purposes. 3) Short-term data use for the current interaction that is not used to build a profile. 4) Servicing transactions and accounts (e.g., customer service, maintaining and servicing accounts, customer verification, payment processing) and providing services on behalf of business or service provider. 5) Undertaking internal research for technological development and demonstration. 6) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. 7) To share the personal information with service providers to carry out other business purposes. For 1-7, this information is not sold to third parties.

      G. We collect geolocation Data. For example, information that can be used to determine a device’s physical location. For example, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement, or Zoom data for employees. The purpose for this collection is: 1) For our internal operation purposes. 2) Fraud and security detection. 3) Debugging to identify and repair errors. 4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. 5) To share the personal information with service providers to carry out other business purposes. For 1-5, this information is not sold to third parties.

      H. We collect sensory or Surveillance Data. For example, audio, electronic, visual, thermal, olfactory, or similar information that can be linked or associated with a particular consumer or household. The purpose for this collection is: 1) To fulfill or meet the reason for which the information is provided. 2) For our internal operation purposes. For 1-2, this information is not sold to third parties.

      I. We collect professional or Employment-Related Information: For example, compensation, evaluations, performance reviews, personnel files and current and past job history. The purpose for this collection is: 1) To fulfill or meet the reason for which the information is provided. 2) Short-term data use for the current interaction that is not used to build a profile. 3) To share the personal information with service providers to carry out other business purposes. For 1-3, this information is not sold to third parties.

      J. We collect education Information (defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99)): Education records directly related to a student maintained by an education institution or party acting on its behalf, for example, non-public information that can be used to distinguish or trace an individual’s identity in relation to an educational institution either directly or indirectly through linkages with other information. The purpose for this collection is: 1) To fulfill or meet the reason for which the information is provided. 2) Short-term data use for the current interaction that is not used to build a profile. 3) To share the personal information with service providers to carry out other business purposes. For 1-3, this information is not sold to third parties.

    • Sensitive Personal Information

      A. We collect social Security Number, Driver’s License, State Identification Card, or Passport Number. The purpose for collection is: 1) To perform services or provide goods you request and reasonably expect from us. 2) To perform services for our business needs such as maintaining accounts, providing customer service, providing financing, verifying customer information, processing payments, providing analytics services, storage, and to fulfill orders. For 1-2, this information is not sold to third parties.

      B. We collect account log-in, financial account, debit card, or credit card number when provided with any required security or access code, password, or credentials allowing access to an account. The purpose for collection is To perform services for our business needs such as maintaining accounts, providing customer service, providing financing, verifying customer information, processing payments, providing analytics services, storage, and to fulfill orders. This information is not sold to third parties.

      C. We collect precise geolocation Information. The purpose for this collection is: 1) To perform services or provide goods you request and reasonably expect from us. 2) To detect, prevent, and investigate security incidents involving your information. 3) To investigate or curtail malicious, fraudulent, or illegal actions directed at us and to prosecute those responsible. 4) To enhance your experience on our website in real time, so long as we do not disclose your information to a third party. For 1-4, this information is not sold to third parties.

      D. We collect racial or ethnic origin, religious or philosophical beliefs, or union membership. The purpose for this collection is to perform services or provide goods you request and reasonably expect from us. This information is not sold to third parties.

      E. We collect contents of a consumer’s mail, email, and text messages (unless we are the intended recipient of the communication). The purpose for this collection is to perform services or provide goods you request and reasonably expect from us. This information is not sold to third parties.

      F. We collect biometric information for the purpose of unique identification. The purpose for this collection is to perform services for our business needs such as maintaining accounts, providing customer service. This information is not sold to third parties.

      PLEASE NOTE: Rightly does not collect any sensitive personal information for the purpose of inferring characteristics about any consumer. Therefore, we are not required to include a “Limit My Sensitive Personal Information” link on our website.

    • Data Retention
      We will retain your user information and documentation for the retention period required by law, and may occasionally retain it beyond the required period, if deemed to be reasonably necessary to fulfill an ongoing business need (for example, account recovery), or to comply with applicable tax, legal or accounting requirements.

      When we have no ongoing legitimate business need to use your user information, we will either delete, anonymize, aggregate, or de-identify it, or if this is not possible (for example, because your personal information has been stored in back-up archives), then we will securely store your personal information and prevent any further processing of it, until deletion is possible. When we dispose of personal information, we use reasonable procedures designed to erase or render it unreadable (for example, shredding documents and wiping electronic media).

      The following principles help guide the length of our retention of records involving personal information:

      1)Minimize retention periods to protect the privacy of our users, while adhering to governing regulations.
      2)Maintain appropriate retention periods for the business purpose in which the records were collected.
      3)Maintain appropriate retention periods to ensure the support, operations, and security of the Rightly environment.
      4)Leverage Legal Counsel to determine when it is appropriate to share data beyond Rightly or third party vendors we contract with, or concerning the preservation of data in response to litigation or law enforcement requests.
      Please note that Personal Information does not include publicly available information that is lawfully made available from federal, state, or local government records, or information that a business has a reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media; or information made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience; or de-identified or aggregated consumer information.


      We will not collect additional categories of personal information without providing you with a new Notice at Collection disclosing those categories.

      We share your personal information with third parties for the purpose of providing contracted or requested services, or to carry out a business purpose such as information security support, or employment/HR services.

    • Do Not Sell / Share My Personal Information
      You have the right to request that Rightly and our service providers not sell or share certain Personal information that Rightly has collected from you to a third party, outside of information necessary to conduct certain business purposes (ie: payroll/HR functions). You can exercise that right at any time, by emailing us at: [email protected]

    • California Privacy Policy
      This CA Privacy Notice specifically addresses applicable California laws and the privacy practices of Zero Realty, Inc. d/b/a Rightly Realty and its affiliates (collectively, “Rightly,” “we,” “us,” or “our”) in providing Services (as defined in the Privacy Policy) to California residents. When you use the Services, you are consenting to the collection, transfer, manipulation, storage, retention, disclosure and other uses of your information by Rightly and its Affiliates as described in this CA Privacy Notice and the Privacy Policy.

      "Agents / Realtors”: are people and other entities we employ or contract with, including inhouse salaried or indepdent licensed real estate salespersons and brokers, that may offer or provide services to you. This CA Privacy Notice only governs the handling of personal information Rightly collects directly, or for which agents input into the Rightly platform or portal. This policy does not govern personal information or sensitive personal information retained or stored outside of the site, platform or portal, and thus you will be governed by other privacy terms, if any, of the websites or services through which you are interacting with outside of Rightly. If an agent collects your personal information and it is not stored or retained on our platform, portal or website we will be unable to process your opt-out request, and you would need to contact the entity with your data directly to change your privacy preferences. All other defined terms used in this CA Privacy Notice shall have the same meanings included in the Privacy Policy.

    • California Privacy Rights: Shine the Light Law
      California’s Shine the Light law (Cal. Civ. Code § 1798.83) permits users of the Services that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request or opt-out, please send an e-mail to [email protected] or send us a request via our webform located on our website.

    • California Privacy Rights: Online Privacy Protection Act (“CalOPPA”)
      California’s Online Privacy Protection Act (Bus. & Prof. Code § 22575) requires operators of a commercial website or online service that collect personally identifiable information as defined under CalOPPA (“PII”) about California consumers through the Internet to satisfy certain requirements. For more information about our tracking practices, please review Section 9. If you want to review and request changes to the handling of your PII, collected through the Site (as defined in the Privacy Policy) or our Services, please send an email to [email protected] or send us a request via our website form.

    • California Privacy Rights: California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”)
      As defined under the CCPA and further revised by the CPRA, if you are a California “Consumer,” you have certain rights with respect to the collection, use, transfer, retention, selling, sharing, and processing of your “Personal Information.” We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified, the retention of your information is necessary to fulfill a service or business objective, or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us directly through the methods specified in section 6: Individual Rights, Control, and Choices. Only you or your Authorized Agent (as defined herein), may make a verifiable consumer request related to your Personal Information.

    • Collection of Personal Information

      When California Consumers access the Site, Platform, Portal, use the Services, or contact Rightly, we may collect the following Personal Information: Customer Records Information, such as one’s name, address, email address, social security number, driver’s license, telephone number, or financial information, taken to assist you in the purchase or sale of property and process your transaction; Characteristics of a Protected Class, such as your age or race, in order to process your transaction; Professional or employment information, such as your current occupation, in order to process your transaction, or employment with Rightly (if applicable); and Inferences derived from public record information (not personal characteristics), such as what type of property you may be most interested in, thus enabling us to market to you more effectively. The categories identified as collected in the tables above were collected from the following categories of sources:

      A) You directly,

      B) Our real estate agents,

      C) Advertising networks,

      D) Internet service providers,

      E) Data analytics providers,

      F) Government entities,

      G) Operating systems and platforms,

      H) Social networks,

      I) Data brokers.

      Selling and Sharing of Personal Information of Minors In the preceding twelve (12) months, we have not knowingly sold Personal Information about consumers under the age of 16.

      Individual Rights, Controls, and Choices

      Summary of Your Rights

      California consumers have certain legal rights related to their Personal Information, as described in greater detail below:

      The right to request information about personal information collected about you; The right to request disclosure of categories of personal information a business shares or discloses; The right to access personal information in a portable format; The right to opt out of the sharing of personal information to a third party; The right to correct your inaccurate personal information; The right to request deletion of personal information; and The right to equal service and price, regardless of whether they exercise their privacy rights. Right to Know About Personal Information Collected, Disclosed, or Sold.

      You have the right to request that Rightly disclose the Personal Information it collects, uses, and discloses about you to third parties.

      Upon our receipt of a verifiable request, you will receive the following information about you:

      a. Categories of Personal Information Rightly has collected;

      b. Categories of sources from which that Personal Information was collected;

      c. The business or commercial purpose for which the Personal Information was collected;

      d. The categories of third parties with whom Rightly disclosed the Personal Information for a business purpose; and

      e. The categories of Personal Information that Rightly disclosed to third parties.

      f. Specific pieces of Personal Information Rightly has collected about you.

      This information will be provided to you free of charge, unless Rightly determines that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.

      Right to Opt-Out of Third-Party Sharing (Do Not Sell/Share My Personal Information)

      You have the right to request that Rightly and our service providers not sell or share certain Personal information that Rightly has collected from you to a third party, outside of information necessary to conduct certain business purposes (ie: payroll/HR functions). You can exercise that right at any time, by clicking the “Do Not Sell/Share My Personal Information” link available on our website in our dedicated Privacy Center.

      You can also request an opt out by emailing us at: [email protected].

      Right To Correct

      You have the right to request that Rightly correct inaccurate Personal information about you that Rightly maintains. We may request documentation from you to determine the accuracy of the information we have maintained. If you provide us documentation either upon our request or through your own initiative, that documentation will only be used or maintained by us for the purpose of correcting your personal information and complying with our recordkeeping requirements under the CCPA and/or CPRA. We may deny your request if we have previously denied your same request to correct an alleged inaccuracy in the past six (6) months, unless you provide new or additional documentation that the information at issue is inaccurate.

      As an alternative to correction, we may delete the inaccurate information if it does not negatively impact you or if you consent to this deletion. We reserve the right to deny this request if allowed under law, or if we determine that the contested information is more likely than not accurate, based on the totality of circumstances. You can submit a correction request through a verified consumer request. That process is described below in the section, “Submitting a Verified Consumer Request.”

      Right to Deletion

      You have the right to request that Rightly and our service providers delete certain Personal Information about you that Rightly has collected from you, or shared with service providers. Rightly shall delete your Personal Information upon receipt of a verifiable request.

      Your deletion rights are subject to several legal exceptions, and we are not required to comply with a request to delete your Personal Information if applicable law permits our retention of your Personal Information and it is necessary for Rightly or our service providers to maintain the Personal Information for the following reasons:

      A. To complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by the consumer, or reasonably anticipated by the consumer within the context of a business’ ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer;

      B. To help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes;

      C. To debug to identify and repair errors that impair existing intended functionality;

      D. To exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law;

      E. To comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the California Penal Code;

      F. To engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the business’ deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if the consumer has provided informed consent;

      G. To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business and compatible with the context in which the consumer provided the information; and

      H. To comply with a legal obligation.

      Submitting A Verified Consumer Request

      You can submit your verified consumer request by emailing us at [email protected]. You may also submit these requests online here through a webform located online within our dedicated Privacy Center, or call us at 858-533-7958.

      The response to a request to know will provide all personal information collected and maintained about you since January 1, 2022, unless doing so proves impossible or would involve disproportionate effort. Please note that we are not required to provide personal information to you more than twice in a twelve (12) month period. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

      If you submit a request that is not through one of these designated methods or is deficient in some manner unrelated to verification, we will provide you with information on how to submit the request or remedy any deficiencies.

      Once we receive your verifiable consumer request, we will confirm receipt of the request within ten (10) business days. We will respond to your request within forty-five (45) calendar days, if we are able to verify your identity. Requests for deletion will require a separate confirmation that you want your information deleted. We will request an additional 45 days to respond substantively, if needed to fulfill your request.

      If requests from you are unfounded or excessive, in particular because of their repetitive character, we may either charge a reasonable fee or refuse to act on the request, notifying you of our reason for refusing to act. If we determine that the request warrants a fee, we will notify you of the reason for that determination and provide you with a cost estimate before completing your request.


      Please note that, in responding to your request, we are not permitted to disclose or provide you with your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. However, we will inform you with sufficient particularity that we have collected the type of information without disclosing the actual data.

      Requests to Know or Delete for Child Under the Age of 16: We do not knowingly collect information of minors under the age of 16.

      Verifying Consumer Requests

      Rightly provides California Consumers with the ability to submit requests through a webform located on our website, phone number at 858-533-7958, and our email address [email protected]. Rightly must verify that the person requesting information or deletion is the California Consumer about whom the request relates in order to process the request. To verify a California Consumer’s identity, we may request up to three pieces of Personal Information about you when you make a request to compare against our records. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in your request to verify your identity and will delete any information you provide after processing the request. Rightly reserves the right to take additional steps as necessary to verify the identity of California Consumers where we have reason to believe a request is fraudulent.

      Authorized Agents

      You may choose a person registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, Rightly requires that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with Rightly. Failure to do so may result in Rightly denying your request.

      Our webform includes an affidavit to submit if an Authorized Agent is submitting a consumer request on behalf of a California consumer. Alternatively, an Authorized Agent may e-mail proof of signed permission along with a copy of their identification and have the consumer directly confirm with us that they provided permission to submit the request on their behalf, by sending an e-mail to [email protected].

      Right to Equal Service

      Rightly will not discriminate against you because you exercised any of your rights, including, but not limited to, by:

      A. Denying goods or services to you;

      B. Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

      C. Providing a different level or quality of goods or services to you;

      D. Retaliating against you, as an employee, applicant for employment, or independent contractor; or

      E. Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

      We comply with all applicable California laws when providing the Services and honoring your right to equal service. Please note that any differential in Services offered may be related to the amount or quality of data or information we have compiled about you as that data or information is required for the Services, and not on your right to equal service under the CCPA and/or CPRA.

      Opt-Out Preference Signals

      RightlyRealty.com employs technology that is compatible with certain opt out preference signals such as global privacy controls (on the browser or browser extensions that support such a signal). Please adjust the preferences within your personal browser, or browser extension if you wish to utilize this function.

      Data Retention

      We will retain your user information and documentation for the retention period required by law, and may occasionally retain it beyond the required period, if deemed to be reasonably necessary to fulfill an ongoing business need (for example, account recovery), or to comply with applicable tax, legal or accounting requirements.

      When we have no ongoing legitimate business need to use your user information, we will either delete, anonymize, aggregate, or de-identify it, or if this is not possible (for example, because your personal information has been stored in back-up archives), then we will securely store your personal information and prevent any further processing of it, until deletion is possible. When we dispose of personal information, we use reasonable procedures designed to erase or render it unreadable (for example, shredding documents and wiping electronic media).

      The following principles help guide the length of our retention of records involving personal information:

      A. Minimize retention periods to protect the privacy of our users, while adhering to governing regulations.

      B. Maintain appropriate retention periods to ensure the support, operations, and security of the Rightly environment.

      C. Leverage Legal Counsel to determine when it is appropriate to share data beyond Rightly or third party vendors we contract with, or concerning the preservation of data in response to litigation or law enforcement requests.

      Please note that Personal Information does not include publicly available information that is lawfully made available from federal, state, or local government records, or information that a business has a reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media; or information made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience; or de-identified or aggregated consumer information.

      What About Tracking Technologies and Do Not Track Signals? Tracking Disclosures: We may use tracking technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). We collect this information for both IT debugging purposes, and to provide us with valuable information used when considering possible web and mobile enhancements.We will comply with web browser “do not track” signals that you may set in your web browser regarding the collection of Personal Information about your online activities over time and across third-party websites or online services, as recognized by many state Attorney General offices. You may also opt out of these practices at any time by emailing “Do Not Sell/Share My Personal Information” to [email protected].

      What Terms Apply to California Employees and Job Applicants? If you are a California job applicant, specific terms in the Your California Privacy Rights notice will apply to the collection of your Personal Information.

      If you are a California employee, specific terms in the Your California Privacy Rights notice will apply to the collection of your personal information.

      What Happens When There Are Changes To This CA Privacy Notice?

      We may amend this CA Privacy Notice from time to time. Use of information we collect now is subject to the Privacy Policy as supplemented by this CA Privacy Notice in effect at the time such information is collected unless we obtain your consent for another purpose. If we make material changes to this CA Privacy Notice, we will publicly post an updated version of this CA Privacy Notice for your review.

      What If I Have Questions Or Concerns?

      If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to [email protected].