Privacy Policy

1. Personal information we collect

We collect the following categories of personal information about our users, prospects and website visitors. Some apply only when you use the related feature, such as billing details if you pay us. These are also the categories we have collected in the past 12 months, to the extent those features were in use. Information we process for agents and brokerages as their service provider is covered in Section 3, not here.

Sources. We collect personal information from you, for example when you request access, create an account or contact us; automatically from your browser or device (see our Cookie Policy); from your organization, such as a brokerage that invites you; from public sources such as the Department of Real Estate license lookup and public property records; and from service providers that help with hosting, analytics, security and fraud prevention.

Why we use it. We use personal information to:

• provide, operate and support the Services, including accounts, licenses, organizations and AI features;
• process payments and manage licenses, if you pay us;
• verify real estate licenses and prevent fraud and abuse;
• send service messages about your account, security, billing and changes to our terms;
• send marketing emails, and marketing texts if you opt in (Section 6);
• promote the Services;
• measure, analyze and improve the Services;
• show labeled advertising from Sponsors, if we offer it (Section 8);
• secure, debug and maintain the Services;
• comply with law, respond to legal process, and enforce our Terms of Use; and
• carry out a merger, financing, acquisition or sale of assets, subject to this policy.

Who we disclose it to.

• Service providers and contractors that process it for us under written contracts that restrict their use of it: cloud hosting and storage, website analytics, AI model providers, email and text delivery, support, payments, security and fraud prevention, and professional advisors.
• Your organization. If you join a brokerage or team account, its owners and admins can see your name, email, profile photo and license use, and they manage your access.
• People you choose, such as visitors to the public pages you publish, people you share a listing with, and a Sponsor you ask to contact you (Section 8).
• Authorities and others when the law requires it, or when needed to protect the rights, property or safety of Joatani, our users or others.
• A successor in a merger, acquisition, financing or sale of all or part of our business.

De-identified and aggregated information. We may use and disclose information that has been de-identified or aggregated so that it no longer identifies anyone, for any lawful purpose. We keep it in de-identified form, do not try to re-identify it, and require anyone we give it to to do the same.

Information about other people. If you give us information about someone else, such as a colleague you invite to your organization, you confirm that you have the right to share it and to have us use it as this policy describes.

2. Sensitive personal information

The only sensitive personal information we collect is your account log-in and password. We use and disclose it only for the purposes the CCPA regulations allow without a right to limit (Cal. Code Regs. tit. 11, § 7027(m)), such as providing the Services you request, keeping them secure, preventing fraud and complying with law. We do not use it to infer characteristics about you. For that reason, we do not offer a separate right to limit its use.

3. Information we process for agents and brokerages

When a real estate agent, team or brokerage (a “Customer”) uses Joatani to host an open house or publish a listing page, we collect information on the Customer’s behalf (“Customer Personal Information”). This includes:

• name, email, phone and the answers visitors give to the Customer’s sign-in questions;
• notes, follow-up status and engagement scores that the Customer’s team adds or the Services generate; and
• device and log information needed to run the sign-in page securely.

Who controls it. The Customer decides what is collected and how it is used, and the Customer’s privacy policy applies to it. We process it as the Customer’s service provider under a written contract (our Terms of Use, Section 20, and any data processing addendum).

What we use it for. We use Customer Personal Information only to provide the Services to that Customer: hosting its sign-in and listing pages; recording sign-ins; showing them to the Customer and the people it authorizes; generating engagement scores, summaries and follow-up suggestions; producing the exports and reports it requests; delivering emails and texts that the Customer sends; storing and backing up the information; securing the Services; providing support; and other purposes the CCPA allows a service provider.

What we do not do with it. We do not:

• sell or share it, or place advertising cookies or pixels on open house sign-in pages or public listing pages;
• use it for Joatani’s own marketing or advertising, or to choose or target Sponsor ads;
• combine it with information we collect in our own right, except as the CCPA allows, such as for security;
• give it to a lender, title or escrow company or other Sponsor, unless the visitor asks to be contacted by that named Sponsor; or
• let our AI providers use it to train their models.

Messages to visitors. If a Customer sends texts or emails to visitors through the Services, the Customer is the sender and relies on consent it collects. To stop them, reply STOP to a text, use the unsubscribe link in an email, or contact the Customer.

Retention. Sign-ins expire 12 months after the visitor signs in, unless the Customer deletes them sooner, and are removed from our live database within 24 hours of expiring. Backup copies may remain for up to about 91 days and are used only for recovery. Our visitor privacy notice gives more detail. If a Customer closes its account, we delete its Customer Personal Information within 90 days, apart from backups.

Requests from visitors. If you signed in at an open house, contact the agent or brokerage that hosted it to access, correct or delete your information, or to opt out of its marketing. You can also ask us to delete your sign-ins by emailing privacy@joatani.com, as our visitor privacy notice explains. We pass other requests to the Customer within 10 business days and help it respond.

4. Retention

We keep each category of personal information for the period below, or until you ask us to delete it, unless we need it longer for a reason in the paragraph after the table. Account log-in details and any inferences are kept with the account information they relate to.

We may keep information longer where needed to comply with law, resolve disputes, enforce our agreements or prevent fraud and abuse. Deleted information may remain in backups for up to about 91 days until they are overwritten.

5. Sale and sharing

We do not currently sell or share personal information, and we have not done so in the past 12 months. (“Share” is the CCPA’s term for disclosing personal information for cross-context behavioral advertising.) We do not use advertising cookies or pixels, and we do not upload customer lists to advertising platforms. We do not disclose personal information to third parties for their own direct marketing purposes unless you first agree to it, for example by asking a named Sponsor to contact you.

If this changes. If we decide to sell or share personal information in the future, for example by using advertising cookies on our marketing website, we will first update this policy and our notices at collection, tell you in advance as Section 16 describes, add a “Do Not Sell or Share My Personal Information” link, and ask for your permission before setting advertising cookies. We will not sell or share personal information we collected while this policy said we do not, unless you consent. Information we process for agents and brokerages (Section 3) and mobile opt-in data (Section 6) will never be sold.

Global Privacy Control. We treat a Global Privacy Control (GPC) signal from your browser as a request to opt out of any sale or sharing of your personal information, now and if our practices change.

Do Not Track. We do not respond to browser “Do Not Track” signals because there is no common standard for them. We do honor GPC. We do not allow advertising networks or other third parties to use our Services to track your activity across other websites over time.

Consumers under 16. We do not knowingly sell or share the personal information of consumers under 16.

6. Marketing emails and texts

Email. If we send you marketing emails, each one has an unsubscribe link, and we honor unsubscribe requests within 10 business days.

Texts. We send recurring automated marketing texts only if you give your prior express written consent by checking a box that is not pre-checked. Consent is not a condition of any purchase. Message frequency varies, and message and data rates may apply. Reply STOP to opt out, or tell us in any other reasonable way, and reply HELP for help. We send marketing texts only between 8 a.m. and 9 p.m. your local time.

Mobile information is not shared. We do not sell or share mobile phone numbers, text message opt-in data or consent with third parties or affiliates for their marketing or promotional purposes. We disclose them only to the service providers that deliver our messages.

Service messages. We may still send you account, security, billing and legal notices after you opt out of marketing.

7. AI features

Some features use, or will use, artificial intelligence, for example to draft text, summarize visitor answers and notes, suggest follow-ups or help prepare market analyses. Outside AI model providers that run these features act as our service providers.

• What AI providers receive: only the content the feature you use needs, such as listing details or a visitor’s answers and notes.
• No training by AI providers: we use them under business terms that do not allow them to use your information, or Customer Personal Information, to train or improve their models, and that limit how long they keep it.
• Our own improvements: we may use de-identified and aggregated information, and feedback you give us on AI output, to improve our features. We do not use one Customer’s Customer Personal Information to improve features for other Customers.
• Engagement scores: scores help agents decide whom to follow up with first. Joatani does not use them, and our Terms of Use prohibit Customers from using them, to make decisions about anyone’s housing, credit, insurance, employment or other significant opportunities.
• Accuracy: AI output can be wrong or incomplete. It is not legal, tax, financial or real estate advice, so review it before you rely on it.

8. Sponsor advertising

Joatani may sell advertising space in the Services to lenders, mortgage brokers, title, escrow, insurance, home warranty, inspection and other real estate settlement service providers (“Sponsors”). This is advertising. We do not refer you to Sponsors or take referral fees. When we offer Sponsor ads, they work as follows:

• Sponsor ads are labeled “Sponsored,” say they are paid ads shown by Joatani and not chosen or endorsed by the hosting agent, and show the Sponsor’s name and, for lenders and mortgage brokers, its NMLS number.
• Sponsor ads appear only at the end of the open house sign-in, after the visitor has signed in. We decide which Sponsors appear, using neutral criteria such as a listing’s location and the ad space available. Sponsors cannot buy placement on a particular agent’s, team’s or brokerage’s pages. When we show several Sponsors together, we list them in random order. Agents and brokerages do not choose them, and we do not use open house visitor information or your personal profile to choose or target them.
• We do not rank Sponsors or compare their rates or terms, we never describe a Sponsor as recommended, preferred or approved, and our AI features do not recommend Sponsors.
• We give your information to a Sponsor only if you contact it yourself, or check a box asking that named Sponsor to contact you. Because you direct that disclosure, it is not a sale. The Sponsor then uses your information under its own privacy policy.
• Sponsors pay us flat fees for advertising space. Those fees do not depend on whether you see, click, contact, apply with or close a transaction with a Sponsor, and we do not receive or pay any fee for referring you. You are free to choose any provider. See our Terms of Use, Section 9.

9. Your California privacy rights

If you are a California resident, you have the right to:

• know what personal information we have collected about you, including the categories, sources, purposes and recipients, and to get a copy of the specific pieces in a portable format. If we keep information for more than 12 months, you can ask for information collected on or after January 1, 2022;
• delete personal information we collected from you;
• correct inaccurate personal information;
• opt out of the sale or sharing of your personal information (Section 5); and
• not be discriminated or retaliated against for using these rights.

We do not offer a right to limit the use of sensitive personal information because we use it only for the purposes described in Section 2. We do not use automated decision-making technology to make significant decisions about consumers.

Limits on these rights. These rights are subject to the exceptions in the CCPA. For example, we may keep information we need to complete a transaction or provide a service you asked for, secure the Services, fix errors, comply with legal obligations, or use internally in ways you would reasonably expect. We may deny a request we cannot verify, and we may decline requests that are manifestly unfounded or excessive. If we deny a request, we will tell you why.

10. How to make a request

• How: email privacy@joatani.com. You do not need an account. Because we do not sell or share personal information, there is nothing to opt out of today; if that changes, Section 5 explains how to opt out.
• Verification: to protect your information, we will ask you to confirm information we already hold, such as your email address and phone number, or to sign in to your account. Requests for specific pieces of information need a higher degree of verification. Opt-out requests do not need verification.
• Authorized agents: an authorized agent must give us your signed written permission. We may ask you to verify your identity directly with us and to confirm that you gave permission, and we may deny a request from an agent that does not provide proof.
• Timing: we confirm receipt within 10 business days and respond within 45 calendar days. If we need more time, up to 45 more days, we will tell you why.
• Open house visitors: see Section 3.

11. California Shine the Light

We do not disclose personal information to third parties for their own direct marketing purposes unless you first agree to it, as Section 5 describes. California residents may ask us about these disclosures once per calendar year by emailing privacy@joatani.com with “Shine the Light” in the subject line.

12. Security

We use reasonable administrative, technical and physical safeguards designed to protect personal information, and we require our service providers to do the same. No method of transmitting or storing information is completely secure, and we cannot guarantee the security of information you send us. You are responsible for keeping your password confidential. If a security breach affects your personal information, we will notify you as the law requires.

13. Our role

Joatani provides software. We are not a real estate broker, lender, mortgage broker, escrow holder or title insurer, and we do not act as anyone’s agent or fiduciary. Agents, brokerages and Sponsors that use or appear on Joatani are independent of us and responsible for their own practices.

14. Age requirement

The Services are only for people 18 and older. We do not knowingly collect personal information from anyone under 18 and will delete it if we learn that we have.

15. Users outside the United States

The Services are intended only for use in the United States. We and our service providers store and process personal information in the United States and in other countries, including in Europe, where some of our team members and service providers work, under the protections this policy describes. If you access the Services from outside the United States, your information will be transferred to the United States and those countries.

16. Changes

We may update this policy. We will post the updated policy here and change the “Last updated” date. If we make material changes, we will tell you in advance by email or by a notice in the Services, and where the law requires your consent to use information we already hold in a materially different way, we will ask for it. We review this policy at least once a year.

17. Contact

Joatani Inc. · Los Angeles, California · privacy@joatani.com

This policy is available in alternative formats on request. Email privacy@joatani.com.