Privacy Policy Copilot

Last Updated January 22, 2024

Luxury Presence, Inc. (“Luxury Presence”, “we”, “our”) provides various website development, website hosting, online marketing and other related services to our real estate agent and broker customers (the “Services”). This Privacy Policy describes how we handle the personal information that we collect (1) from our real estate professional customers in connection with the Services, (2) from our mobile applications (including Presence Copilot) (the “Mobile Apps”), and (3) from other individuals through our website or other services that link to this Privacy Policy.

This Privacy Policy does not apply to personal information about our customers’ clients or end customers. We process such information on behalf of our customers, as instructed by them, in our capacity as a service provider.

In addition, our Services are designed for businesses and are not intended for personal, family, or household use. Accordingly, we treat all personal information covered by this Privacy Policy as pertaining to individuals acting as business representatives, rather than in their personal capacity.

Personal Information We Collect

Information you provide to us:

Business contact information, such as your first and last name, phone number, and email address.
Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
Financial Information, such as when you pay for certain Services, our payment processor(s) will collect the financial information necessary to process your payments, such as your payment card number and authentication details. Please note, however, that we store only a tokenized version of such information and do not maintain payment card information on our servers.
Marketing information, such as your preferences for receiving our marketing communications, and details about your engagement with those communications.
Social Media Information. We have pages on social media sites like Instagram, Facebook, Twitter and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect personal information that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

Information from Presence Copilot and related Services. We have made available certain products and services that allow our real estate professional customers to interact and collaborate with their clients or prospective clients in connection with the home-buying or home-selling process (the “Client-Facing Services”). If you are a client of one customers who is using a Client-Facing Service (including a Mobile App), we may collect certain information about you when you register an account with us, including your name, email address, and phone number. We may use such personal information in accordance with this Privacy Policy and will only share your personal information with the real estate professional with whom you are doing business or as otherwise set forth in the “Sharing of Your Personal Information” section below.

Automatic data collection. We and our service providers may automatically log 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 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 stored on your device to uniquely identify your browser or to store information or settings in the browser to help you navigate between pages efficiently, remember your preferences, enable functionality, help us understand user activity and patterns, and facilitate 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, operate, and improve our Services and our business;
Communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages;
Provide support, and respond to requests, questions, and feedback.

For research and development. To analyze and improve the Services and to develop new products and services, including by studying use of our Services.

For marketing and advertising. We and our advertising partners may collect and use your personal information for marketing and advertising purposes, including:

Direct marketing. We may from time-to-time send you direct marketing communications via email, phone and text message as permitted by law, including, but not limited to, and notifying you of special promotions and offers. You may opt out of our marketing communications as described in the “Opt out of marketing communications” section below.
Interest-based advertising. We engage our advertising partners, including third party advertising companies and social media companies, to display ads around the web. These companies may use cookies and similar technologies to collect information about your interaction (including the data described in the “Automatic data collection” section above) over time across our Services, our communications and other online services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the “Online tracking opt-out” section below.

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.

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.

To create anonymous data. To create anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services, conduct research, and promote our business.

Sharing of Your Personal Information

Our Sharing: We may share your personal information in the following circumstances:

Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate our Services (such as customer support, hosting, analytics, email delivery, marketing, payment processing, and database management services).
Advertising partners. We may share your personal information with third party advertising companies, including for the interest-based advertising purposes described above.
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.
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.

Your Sharing: For users of the App, you may be able to make your personal information available to other individuals, including:

Other users, such as when you create a profile, post content, and otherwise interact with other users through the App; and
Other businesses, when you participate in offers, promotions and other features available via the App or marketed to you through the App.

Privacy Choices

You have the following choices regarding our collection and use of your personal information:

Access or update your information. If you have registered for an account with us, you may review and update certain information in your account profile by logging into your account.

Opt-out of marketing communications. You can opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the emails you receive from us. If you do so, you will continue to receive service-related and other non-marketing emails until you cease using our services linked to those service updates. You can opt out of marketing-related communications sent by text message by contacting us at [email protected] or responding with “STOP”.

Privacy rights. You have the right to submit requests about your personal information, depending on your location and the nature of your interactions with 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.

To make a request, please email us as provided in the “Contact Us” section below. We may ask for specific information from you to help us confirm your identity. California residents can empower an “authorized agent” to submit requests on their behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

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.

Use the following links to learn more about how to control cookies and online tracking through your browser:

- Firefox; Chrome; Microsoft Edge; Safari
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.
Google Analytics. We use Google Analytics to help us better understand how people engage with the Services by collecting information and creating reports about how users use our Services. For more information on Google Analytics, click here. For more information about Google’s privacy practices, click here. You can opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
Using privacy plug-ins or browsers. You can block our Services from setting cookies used for 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.
Platform opt-outs. Some third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, allow you to opt-out directly by using their opt-out tools. Some of these providers, and links to their opt-out tools, are:
- Google
- Facebook
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:
- Digital Advertising Alliance
- Network Advertising Initiative

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.

Limits on your choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “Contact Us” section below.

Do Not Track. Some Internet browsers can 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

Our website and services can contain links to websites and other online services operated by third parties. In addition, our content can 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.

Information 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’s Privacy

Our services are not intended for use by children under 18 years of age. If we learn that we have collected personal information through our services from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.

Retention

We retain your personal information for as long as appropriate to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for your personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we process personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Cross-Border Processing of Personal Information

Please note that we are headquartered in the United States. To provide and operate our services, it is necessary for us to process your personal information in the United States.

If we transfer personal information across borders such that we are required to apply appropriate safeguards to personal information under applicable data protection laws, we will do so. Please contact us for further information about any such transfers or the specific safeguards applied.

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, for example through posting the Privacy Policy on our services.

Contact Us

Responsible entity. Where you interact with services provided by Luxury Presence, Luxury Presence is the entity responsible for your personal information, and is the data controller in respect of such processing. Where you interact with services provided by one of our customers (such as interacting with the customer website that is managed by Luxury Presence), our customer is the entity responsible for your personal information, and is the data controller in respect of such processing.

You can reach us by email at [email protected]