Privacy Policy

Last updated March 2, 2024.

This Privacy Policy (“Policy”) is presented by Reallo Technologies LLC (“Reallo,” “Company,” “We,” “Us,” or “Our”), which oversees and operates the websites accessible at Reallo.ai, lowincomehousing.ai, and tryreallo.com (collectively referred to as the “Websites”). This governance extends to the Reallo mobile applications (“Apps”) and includes any associated platforms, tools, applications, or services we offer (hereafter collectively termed the “Sites”).

For the purposes of this Policy:

“User,” “Data Subject,” “You,” or “Your” refers to any individual, group, or entity that accesses, uses, or interacts with the Sites in any manner. The terms “User,” “User(s),” “Data Subject(s),” “You,” and “Your” are used interchangeably throughout this document and are intended to inclusively cover all forms of user engagement with the Sites, whether individually or collectively.

Article I: Purpose

The primary aim of this Policy is to delineate the framework within which the Company collects, stores, uses, and shares information gathered through the User(s) engagement with the Sites. The User(s) use of the Sites constitutes the User(s) acknowledgment of, and agreement to, the terms outlined in this Policy. It indicates the User(s) consent to the collection, use, storage, and sharing of the User(s) information as detailed herein.

Article II: Information Collection and Use.

2.01 Collection of Personal Information.

In engaging with the Sites, the User consents to the collection and storage of personal information. This Policy encompasses information obtained directly from the User and through other means and sources as detailed herein. The scope of collected information, subject to the User(s) usage of our Sites or services, includes, but is not limited to:

(a) Personal Information Submission. By interacting with the Sites, the User may provide personal details such as name, email address, phone number, and preferences related to the User(s) housing search. This includes:

Account Information. On account creation, the User may input additional details for use on our Sites, potentially shared with property owners or landlords, including but not limited to employment, income, and credit score data.
Third-Party Services. The User(s) use of specific services may result in the User(s) information being processed by external parties. For instance, transaction processing via the Sites is conducted through third-party payment processors.
Public Contributions and Feature Usage. Contributions made publicly on the Sites, including but is not limited to reviews, and the User(s) use of features like property tours, are collected and used as per this Policy.

(b) Automated Data Collection. The use of cookies and similar technologies by the Company or third parties on the User(s) device is aimed at personalizing and enhancing the User(s) experience on our Sites. The User(s) interaction with these technologies is governed by this Policy.

(c) Additional Data Collections. This includes but is not limited to communications data, location information, usage logs, social media information, media files, and embedded content from third-party sites, each subject to the terms detailed herein.

2.02 General Uses.

The Company hereby stipulates the purposes and means by which personal information of User(s) will be processed, subject to the terms of this Policy. The Company is vested with the authority to:

(a) Facilitate, enhance, and personalize the user experience across all Company-operated platforms, including but not limited to, the provision of services and customer support, property inquiries, and rental application assistance.

(b) Engage in communication with User(s), property owners, landlords, and management entities for purposes including, but not limited to, service provision, dispute resolution, and transaction facilitation.

(c) Implement tailored marketing strategies, including the dissemination of promotional materials, service offerings, and event notifications through various communication channels as consented to by the User.

(d) Conduct verification and accuracy assessments of User information against third-party databases to ensure data integrity and compliance with applicable regulatory standards.

(e) Undertake analytical and market research activities to gauge service engagement levels, user satisfaction, and potential areas for service enhancement or development.

2.03 Third-Party Interactions.

Without prejudice to any other provision of this Policy, The Company reserves the right to engage with third-party entities in the facilitation of certain services as requested by the User. Such engagements include, but are not limited to:

(a) Payment processing services, wherein Users financial information may be processed by designated third-party payment processors.

(b) Credit and background check services, requiring the sharing of user information with third-party agencies for the purpose of rental application processing.

2.04 Security and Fraud Prevention.

The Company is committed to maintaining the integrity and security of User information. As such, the Company shall:

(a) Employ reasonable and appropriate measures to safeguard personal information from unauthorized access, alteration, or dissemination.

(b) Monitor and evaluate transactions and interactions on the Company platforms for the purposes of identifying, preventing, and addressing potential fraud, errors, or other illicit activities.

2.05 Policy Enforcement and Compliance.

The Company reserves the right to enforce this Policy in accordance with applicable laws and regulations. This includes, but is not limited to, the issuance of notices, alerts, and implementing corrective measures as necessary to ensure compliance with the terms herein and applicable legal obligations.

2.06 Data Aggregation and Anonymization.

For the purposes of general marketing and analytical considerations, the Company may aggregate or anonymize personal information such that it no longer identifies a specific User. Such aggregated or anonymized data may be used to inform business strategies and service offerings.

Article III: Disclosure of Personal Information.

3.01 Scope of Disclosure.

The Company reserves the right to disclose the personal information of its Users under certain conditions as outlined in Article II of this Policy and for other purposes as explicitly communicated to or consented by the User. Such disclosures include, but are not limited to:

(a) Directed Sharing. The Company may share personal information with third-party properties, including names, email addresses, and phone numbers, for purposes related to the facilitation of services requested by the User, such as property tours or rental applications.

(b) Operational Service Providers. The Company may engage with third-party service providers to assist in various operational aspects of the Company’s services. Information will be shared with these providers as necessary to fulfill the services.

(c) Marketing and Third-Party Offer. The Company may share information with third parties for the provision of relevant products, services, or marketing offers.

(d) Legal Compliance and Law Enforcement. The Company may disclose personal information in response to legal processes, law enforcement requests, or as required by law, including but not limited to compliance with the Company’s Terms of Service or this Policy, or to protect the safety of our users or the public.

(e) Business Transfers. The Company may transfer personal information to the involved third party in the event of a merger, acquisition, or sale of assets.

3.02 Communications and Advertising.

(a) Sharing Listing Functionality. The Company offers features allowing Users to share listings with others. The Company does not retain shared contact information for purposes beyond the initial sharing.

(b) Email Preferences. Users may opt-out of marketing communications from the Company. Opting out from one brand does not automatically apply to all affiliated brands.

3.03 Interest-Based Advertising.

The Company engages in interest-based advertising and partners with third parties to display tailored ads. Users may opt-out of such tracking through specified industry mechanisms.

3.04 Privacy Rights.

Users may exercise rights afforded to them under applicable laws regarding their personal information, including access, deletion, and correction requests.

3.05 Third-Party Websites and Services.

This Policy does not extend to third-party websites or services. Users are encouraged to review the privacy policies of third-party entities before sharing personal information.

3.06 Account Security and Data Protection.

The Company employs measures to protect personal information but cannot guarantee absolute security. Users are responsible for maintaining the confidentiality of their account information.

3.07 Minors.

The Company products and services are not intended for individuals under the age of 13.

Article IV: California Consumer Privacy Addendum.

This Addendum to the Privacy Policy of Reallo Technologies LLC (“Company”) applies exclusively to consumers residing within the State of California, pursuant to the California Consumer Privacy Act (CCPA) and other applicable California state privacy laws.

4.01 Collection and Processing of Personal Information.

In the preceding twelve (12) months, consistent with the provisions outlined in Article II, the Company has collected the following categories of personal information:

(a) Identifiers. This includes, but is not limited to, real names, aliases, postal addresses, unique personal identifiers, online identifiers, Internet Protocol (IP) addresses, email addresses, and account names derived from account registrations on our Sites.

(b) Consumer Records. As defined under the California Customer Records statute, this encompasses the aforementioned identifiers along with self-reported employment, income, and credit score information, particularly for rental application purposes.

(c) Commercial Information. Records detailing personal property, goods or services purchased, considered, or other purchasing or consumption histories.

(d) Internet or Other Similar Network Activity. This includes, but is not limited to, browsing and search history, interaction with our Sites, applications, or advertisements.

(e) Geolocation Data. Collected upon authorization in our Apps.

(f) Audio Information. This includes recordings and transcriptions of calls made to properties, with prior notification of recording.

(g) Sensitive Personal Information. Including account login credentials, government-issued identifiers for rental applications, precise geolocation data, and the content of emails exchanged with properties.

(h) Inferences. Drawn from the collected information to create a consumer profile reflecting preferences, behaviors, psychological trends, and aptitudes.

4.02 Purposes for Processing Personal Information.

The Company uses the personal information collected for operational purposes as elaborated in Article II of this Policy. Additional uses include, but are not limited to:

(a) Auditing consumer interactions and transactions for compliance and optimization.

(b) Enhancing security and integrity, including fraud detection and prosecution.

(d) Short-term, transient use, without further disclosure or profile creation beyond the current interaction.

(e) Provision of services, including property information dissemination, communication facilitation, account maintenance, transaction processing, and advertising and marketing services.

(f) Conducting internal research for technological development and service improvement.

(g) Quality and safety verification or enhancement of services or devices.

4.03 Sources of Personal Information.

The personal information processed by the Company is sourced from individuals directly, devices interacting with our Sites or Apps, communications (such as emails and calls), and third-party partners, as detailed in Article II.

4.04 Additional Notice for California Consumers

The ensuing section(s) applies specifically to California residents.

4.05 Disclosure of Personal Information.

Pursuant to the operations and functionalities of the Company, and in alignment with the operational purposes as outlined in this Policy, The Company may disclose personal information to third parties. This disclosure is contingent upon the purposes detailed in Section II or under circumstances explicitly communicated to or agreed upon by the User.

Notwithstanding, the Company delineates that:

(a) Personal information is not monetarily sold. However, within the last twelve months, certain data such as online identifiers, interaction details with our Sites, and insights garnered from such interactions have been shared with third-party companies for cross-context behavioral advertising, which under California law might be construed as a “sale” or “sharing”.

(b) The Company expressly refrains from selling personal information of individuals under the age of sixteen (16) or sharing such information for behavioral advertising.

4.06 Rights of California Consumers.

California residents are accorded specific rights concerning their personal information, including but not limited to:

(a) Right to Know and Access. Request disclosure of the categories and specifics of personal information collected, including the sources, purposes, and any third parties with whom the information was shared.

(b) Deletion Rights. Request deletion of personal information collected by the Company.

(d) Right to Opt Out. Direct the Company to cease “selling” personal information or sharing it for cross-context behavioral advertising.

(e) Right to Non-Discrimination. Promise that exercising CCPA rights will not result in discriminatory treatment by the Company, albeit price or service differences directly related to the value of personal information are permissible.

To exercise these rights, California consumers may contact the Company through the provided mechanisms, including the Company’s designated privacy contact (privacy@reallo.ai). The Company commits to verifying the identity of the requestor prior to fulfilling any request.

4.07 Agent Authorization.

California consumers may designate an authorized agent to act on their behalf concerning their CCPA rights, subject to necessary verification by The Company.

4.08 Metrics and Reporting.

The Company shall maintain and disclose metrics regarding the handling of privacy rights requests from California residents for the period January 1, 2024, to December 31, 2024, including the volume of requests received, addressed, and the median time to respond.

4.09 Additional Provisions.

(a) California Rights on Direct Marketing. Consumers may inquire about the sharing of personal information with third parties for direct marketing purposes.

(b) Do Not Track Disclosures. The Company does not currently take actions in response to browser Do Not Track signals or similar mechanisms.