SavvyPhone Privacy Notice

Last revised: May 22, 2023

1. Introduction

SavvyPhone, LLC d/b/a SavvyCard ("SavvyPhone" or "we" or "us") respect your privacy and are committed to protecting it through our compliance with this policy.

This Privacy Notice (our "Privacy Notice") describes the types of information we may collect from you or that you may provide when you visit the website www.SavvyCard.com ("Website") or use or subscribe to our services available on or through the Website or otherwise, including the use of the SavvyCard^® product and service ("Services") and our practices for collecting, using, maintaining, protecting, and disclosing that information. In addition, your use of our Website and the Services is governed by our Terms of Use.

This policy applies to information we collect:

• on our Website or on or through our Services;
• in email, text, and other electronic messages between you and our Website or our Services; and
• when you interact with our advertising on third-party websites and services, if that advertising includes links to this policy.

It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by SavvyPhone or any third-party;
• us related to your or any other individual's employment or potential employment with us; or
• any third party, including:
• through any application or content (including advertising) that may link to or be accessible from the Website or as part of the Services;
• any third party with whom you may share your SavvyCard with or who may have shared their SavvyCard with you;
• any social media site to which you may post information to on or through the Website or the Services.

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, YOUR CHOICE IS NOT TO USE OUR WEBSITE OR OUR SERVICES. BY ACCESSING OR USING THE WEBSITE OR USING OUR SERVICES, YOU AGREE TO THIS PRIVACY NOTICE. THIS PRIVACY NOTICE MAY CHANGE FROM TIME TO TIME (SEE CHANGES TO OUR PRIVACY NOTICE). YOUR CONTINUED USE OF THIS WEBSITE OR OUR SERVICES AFTER WE MAKE CHANGES IS DEEMED TO BE ACCEPTANCE OF THOSE CHANGES, SO PLEASE CHECK THIS PRIVACY NOTICE PERIODICALLY FOR UPDATES.

2. Children Under the Age of 18

Our Website and Services are not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website or the Services. We do not knowingly collect Personal Information from children under 18. If you are under 18, do not use or provide any information on our Website or Services or on or through any of its features or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received Personal Information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18, please contact us through the Contact Us information below.

3. Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website ("Personal Information"):

• by which you may be personally identified, such as name, postal address, e-mail address, telephone number, financial account or credit card data (collected by our payment processor for payment purposes, we do not collect or store your financial account or credit card data on our servers), social media account information (including login name and password), Multiple Listing Service (MLS) account information (including login name and password), and any other identifier by which you may be contacted online or offline;
• that is about you but individually does not reasonably identify you by itself, including information about how you use our Website and Services and demographic data (such as age, language, gender, profession, education level, likes and dislikes, if you choose to provide it); and/or
• about your internet connection, the equipment you use to access our Website and Services and usage details.

We collect this information:

• directly from you when you provide it to us;
• automatically as you navigate through the Website or use our Services. Information collected automatically may include internet, access, and usage details collected by our IT infrastructure in log files and other system operations and administration functions, and information collected through cookies, web beacons, and other tracking technologies; and
• from third parties, for example, public records, the Real Estate Member Organization ("REMO") to which you may belong to, and our business partners.

The information we collect from you on or through our Website or Services are:

• information that you provide by filling in forms on our Website or Services. This includes information provided at the time of registering to use our Websites, subscribing to our service, or requesting further information or services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website or Services;
• records and copies of your correspondence (including email addresses), if you contact us;
• information that you add to your SavvyCard if you use the SavvyCard functionality;
• information that you provide when you enter a promotion or a sweepstakes;
• contact information you provide when you subscribe to one of our newsletters;
• your responses to surveys that we might ask you to complete for research purposes;
• details of transactions you carry out through our Website and Services and of the fulfillment of your orders. You may be required to provide financial information before subscribing to our Services.

You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website or Services or transmitted to other users of the Website or Services or to third parties, including social media or other online services (collectively, "User Content"). You may also share all or part of the information in your SavvyCard with third parties. Your User Content and the contents of your SavvyCard are posted and/or transmitted to others at your own risk. Although we limit access to certain pages of our Website and we limit access to certain features of our Services, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of recipients of your SavvyCard or of other users with whom you may choose to share your User Content. Therefore, we cannot and do not guarantee that your User Content or the contents of your SavvyCard will not be viewed by unauthorized persons.

As you navigate through and interact with our Website or use our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns:

• details of your visits to our Website or use of our Services. This includes traffic data, location data, logs, referring/exit pages, date and time of your visit to our Website and your use of our Services, error information, clickstream data, and other communication data and the resources that you access and use on the Website and/or in the Services;
• Statistical information about your use of the Services, including how often you share and use each type of SavvyCard or use other particular features and functions of the Services; and
• Information about your computer and internet connection, i.e. your IP address, domain server configuration, device unique identifiers, device type and configuration (including, for example, screen size and resolution), operating system, and browser type.

The information we collect automatically may include Personal Information or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and Services and to deliver a better and more personalized service by enabling us to:

• estimate our user size (and potential user size) and usage patterns;
• store information about your preferences, allowing us to customize our Website and Services according to your individual interests;
• not show you certain information again after you have viewed it, dismissed it, or otherwise expressed that you do not have an interest in it;
• speed up your searches; and
• recognize you when you return to our Website or use our Services (including, for example, so you don't have to re-enter your username and password each time you use our Website or Services).

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website or use our Services. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or select this setting you may be unable to access certain parts of our Website or Services. You can find more information about cookies at http://www.allaboutcookies.org and http://youronlinechoices.eu.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
• Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit SavvyPhone, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Some content or applications, including advertisements, on the Website or Services are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website or Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. The third party services we use on our Website and Services include:

• Google Analytics and Other Analytics Providers. We use Google Analytics, a web analytics service provided by Google, Inc. ("Google") and other similar analytics companies to collect certain information relating to your use of the Websites and Services. Google Analytics uses cookies as described above. You can find out more about how Google uses data when you visit our Websites by visiting "How Google uses information from sites or apps that use our services" (located at www.google.com/policies/privacy/partners).
• Microsoft Clarity. We use Clarity in order to better understand our users' needs and to optimize our Website and Services and your experience when using them. Clarity is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don't like, etc.) and this enables us to build and maintain our Website and Services with user feedback. Clarity uses cookies and other technologies to collect certain information relating to your use of the Website and Services. For further details, please see Clarity's privacy policy by clicking on this link. You can opt-out to the creation of a user profile, Clarity's storing of data about your usage of our site and Clarity's use of tracking cookies on other websites by following this opt-out link.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

We may obtain information or supplement information we already have obtained with additional information from public sources or from third parties, including, for example, consumer reporting agencies, social media services, Multiple Listing Services, Associations of REALTORS^®, and REMOs to which you are a member. In some cases, this information may include information by which you may be personally identified, including your name, postal address, e-mail address, and telephone number, and your rights to access, change, and delete this information may be governed by your agreement with that organization.

4. How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information:

• to present our Website and Services to you;
• to provide you with information, products, or services that you request from us, including to post social media ads when you request them;
• to provide you with notices about your account, including expiration and renewal notices;
• if you are a subscriber, to send you information about our products, services, promotions, or newsletters unless you have opted out of receiving them;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• to notify you about changes and service to our Website or Services or any other products or services we offer or provide;
• to notify you about service-related information about the Website or the Services, such as periods of unavailability;
• to communicate with you for customer service;
• to provide you with information about SavvyCards that have been shared with you and to share your information in SavvyCards that you have shared and notifications when this sharing occurs;
• to allow you to participate in interactive features on our Website and Services, including communicating with others who correspond with you through your SavvyCard;
• in any other way we may describe when you provide the information;
• to fulfill any other purpose for which you provide it; and
• for any other purpose with your consent.

We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you, including through targeted advertising. If you do not want us to use your information in this way, please send us an email stating your request at support@savvycard.com. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria and may also collect additional information from you on their own website or service.

5. Disclosure of Your Information

We do not share, sell for monetary value, or otherwise disclose your Personal Information for purposes other than those outlined in this Privacy Notice. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Information that we collect or you provide as described in this Privacy Notice:

• to our subsidiaries and affiliates;
• to contractors, service providers, and other third parties we use to support our business, including IT and infrastructure support, mailing, marketing, data analysis, system security, payment processing, and other similar services. Our payment processor's privacy policies may be found at https://stripe.com/us/privacy.
• to a potential or actual buyer or other successor in the event of a planned or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of SavvyPhone, LLC's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by SavvyPhone, LLC about our Website and/or Services users is among the assets transferred;
• to third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep Personal Information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information;
• to fulfill the purpose for which you provide it. For example, if you give us an email address to share your SavvyCard with, we will transmit the contents of your SavvyCard to the recipients;
• for any other purpose disclosed by us when you provide the information; and
• with your consent.

We may also disclose your Personal Information:

• to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes. This includes disclosing your Personal Information to credit reporting agencies and collection agencies; and
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of SavvyPhone, LLC, our visitors, customers, or subscribers, or others (including the public at large). This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We may also disclose data and information related to your access and use of the Services to the organization who has entered an agreement with us to provide you access to the Services, such as your employer, Association of REALTORS^®, or a REMO to which you belong to. This information may include statistical and performance information related to your use of the Services (for example, how often you have shared your SavvyCards or used the Services to advertise your products and services), but will not include any information, data, or other content that you provide to the Services.

6. Choices About How We Use and Disclose Your Information

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with control over your Personal Information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of our Website or our Services may then be inaccessible or not function properly.
• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by contacting us at the Contact Information below.
• Promotional Offers from SavvyPhone. If you do not wish to have your contact information used by SavvyPhone to promote our own or third parties' products or services, you can opt-out by sending us an email stating your request to support@savvycard.com. If we have sent you a promotional email, you may also click an unsubscribe link in such email to be omitted from future email distributions. This opt out does not apply to information provided to SavvyPhone as a result of a subscription, customer service communications, Website or Services experience, sharing or other use of your SavvyCard, or other transactions.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by contacting us at the Contact Information below.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (""NAI") on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info).

7. Accessing and Correcting Your Information

Subject to the below, you can review and change your personal information by logging into the Website and visiting your account profile page. You may also send us an email at support@savvycard.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Your ability to change or delete the personal information we process may be limited if we have received that personal information from a REMO of which you may be a member. Please contact your REMO to have any information changed (changes to your REMO account may take 24 hours or more to be reflected in your SavvyCard). If you wish to delete your information, we can only mark your SavvyCard account as inactive so it is no longer visible to internet searches (this does not apply to SavvyCards you use related to property listings, and such SavvyCards may still contain your contact information). Please contact your REMO to have your information permanently removed and no longer provided to us.

We may not be able to delete portions of your User Content. Your User Content may remain viewable in cached and archived pages as well as on social media pages to which you instructed us to share it. It might also have been copied or stored by third parties or other Website or Services users. Proper access and use of information provided on the Website or in the Services, including User Content, is governed by our Terms of Use.

8. State-Specific Privacy Rights

The law in some states may provide you with additional rights regarding our use of Personal Information. To learn more about any additional rights that may be applicable to you as a resident of one of these states, please see the privacy addendum for your state linked below.

After January 1, 2020, you have the additional rights described in the California Privacy Addendum.

9. Do Not Track Signals

We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

10. Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Our payment processor is contractually required to encrypt payment transactions using SSL technology and to otherwise be compliant with the payment card industry data security standard (PCI-DSS). SavvyPhone only receives the last 4 digits of your credit card information and a representative token of your credit card information (which may only be used by us with our payment processor) for recurring payments.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website or Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out certain information in your SavvyCard, such as health, medical, and other sensitive information. The particular information you share in your SavvyCard may be viewed by any recipient of your SavvyCard. You should use particular caution when accessing the Website or Services from a public or shared computer. We ask that you exit from your account and close your browser at the end of your session accessing and using our Website or Services so that others are not able to view or record your password or other Personal Information.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website or Services. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures deployed on the Website or Services.

11. Consent to Processing of Personal Information In the United States

If you are a resident of the European Economic Area ("EEA"), in order to provide our Website and Services to you, we may send and store your Personal Information outside of the EEA, including to the United States. Accordingly, your Personal Information may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Information.

Your Personal Information is transferred by SavvyPhone to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Information. By using our Website or Services, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Information outside the country where you reside or are located. To ensure your Personal Information is treated in accordance with this Privacy Notice when we transfer it to a third party, SavvyPhone uses Data Protection Agreements between SavvyPhone and all other recipients of your data that include, where applicable, the Standard Contractual Clauses adopted by the European Commission (the "Standard Contractual Clauses"). The European Commission has determined that the transfer of Personal Information pursuant to the Standard Contractual Clauses provides for an adequate level of protection of your Personal Information. Under these Standard Contractual Clauses, you have the same rights as if your data was not transferred to such third country. You may request a copy of the Data Protection Agreement by contacting us through the Contact Information below.

12. Changes to Our Privacy Notice

We may change this Privacy Notice at any time. It is our policy to notify our users of any changes we make to our Privacy Notice by email to the email address specified in your account and/or through a notice on the Website's home page. The date this Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Notice to check for any changes.

13. Contact Information

If you have any questions, concerns, complaints or suggestions regarding our Privacy Notice, have any requests related to your Personal Information pursuant to applicable laws, or otherwise need to contact us, you may contact us at the contact information below or through the "Contact Us" section on our Website.