Privacy Policy of Call It Closed International Realty

Effective Date: December 3rd 2025

Call It Closed International Realty (“CICR,” “we,” “us,” or “our”) is committed to protecting the privacy and security of the personal data we collect from clients, prospective clients, agents, and visitors to our websites, mobile applications, and other services (collectively, the “Services”).

This Privacy Policy describes how we collect, store, use, and protect your Personal Data and outlines your rights regarding this information.

1. Information We Collect and Sources of Data

We collect information that identifies, relates to, describes, or is reasonably capable of being associated with you (“Personal Data”).

1. Categories of Personal Data Collected

• Identifiers and Contact Information: Name, postal address, email address, telephone number, IP address, and unique identifiers (such as a device ID).
• Financial/Commercial Information: Information related to your real estate interests (e.g., property preferences, budget), transaction history, and, for agents, bank account details for commission payments.

1. Sources of Collection

• Directly from You: When you inquire about a property, register for an account, sign up for a newsletter, apply to be an agent, or communicate with us via phone, email, web forms, or text message.
• From Our Agents and Brokers: Information provided by our authorized agents to facilitate services, such as during a property showing or transaction closing.
• Automated Technologies: Through cookies, web beacons, and other tracking technologies when you interact with our website or digital communications.
• Third Parties: From service providers (e.g., mortgage brokers, title companies, virtual tour providers) to complete a transaction, and from public sources (e.g., Multiple Listing Services, public records).

2. How Personal Data is Stored and Used
3. How We Use Your Personal Data

We use your Personal Data for the following business and commercial purposes:

• To Provide Services: To facilitate real estate transactions, provide property listings, schedule showings, and process applications (including agent applications).
• To Communicate: To respond to your inquiries, send administrative and technical notices, and provide customer support.
• Personalization and Marketing: To personalize your experience, present properties tailored to your inferred interests, and send promotional communications about our services, properties, or events (you may opt-out at any time).
• Internal Operations: To improve our Services, analyze usage trends, protect against fraudulent or illegal activity, and maintain the security of our systems.
• Legal Compliance: To comply with applicable laws, regulations, and legal processes, such as anti-money laundering regulations and legal reporting obligations.

1. Data Storage and Retention

• Storage: Personal Data is stored on secure, access-controlled servers, which may be located within the United States or other international jurisdictions where CICR operates or utilizes third-party service providers.
• Retention: We retain Personal Data for as long as necessary to fulfill the purposes for which it was collected, to provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, and to comply with our legal obligations.

3. Data Protection Measures and Sharing Policies
4. Data Protection and Security

We implement a variety of industry-standard administrative, technical, and physical security measures to protect your Personal Data from unauthorized access, disclosure, alteration, and destruction. These measures include:

• Encryption: Using encryption technologies (such as SSL/TLS) to protect data transmitted to and from our Services.
• Access Controls: Restricting access to Personal Data to only those agents, employees, and third-party service providers who require it to perform their job duties.
• Regular Audits: Periodically testing and auditing our security systems and practices.

1. Sharing and Disclosure of Personal Data

We may share your Personal Data with third parties under the following circumstances:

• With Our Affiliates and Agents: To facilitate the delivery of our Services across our international network and to connect you with a CICR agent in your area of interest.
• Service Providers: With vendors, consultants, and other third-party service providers who need access to your information to perform work on our behalf (e.g., website hosting, IT support, analytics, CRM providers).
• During a Real Estate Transaction: With necessary parties such as title companies, mortgage brokers, appraisers, inspectors, and opposing agents/parties as required to complete the transaction.
• Legal Obligations and Protection: To comply with laws, respond to lawful requests and legal process, protect the rights and property of CICR, our agents, customers, and others.
• Business Transfers: In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

We do not sell your Personal Data to third parties for their independent marketing purposes.

4. Compliance with Applicable Privacy Regulations

As an international realty, we aim to comply with the data protection laws in the jurisdictions where we operate or serve clients.

• Global Transfers: If you are a resident of the European Economic Area (EEA), the United Kingdom, or other regions with data transfer restrictions, your Personal Data may be transferred to, stored, and processed in the United States or other countries. We take appropriate measures to ensure your data receives an adequate level of protection in accordance with applicable laws.
• Your Data Rights: Depending on your location and the privacy regulations applicable to you, you may have the right to:
  • Access your Personal Data.
  • Correct inaccurate or incomplete data.
  • Request Deletion of your Personal Data.
  • Object to or Restrict the processing of your Personal Data.
  • Data Portability (receive a copy in a structured, commonly used, and machine-readable format).

To exercise these rights, please contact us using the information in Section 6. We will respond to your request in accordance with applicable law.

5. Messaging Practices (Email, SMS, and Text)

This section specifically governs our use of electronic messaging to communicate with you.

• Consent: By submitting a web form, sending a text message, or providing your phone number and/or email address to a CICR agent, you agree to receive communications from us and our authorized agents, including emails and SMS text messages, concerning your inquiries, property alerts, and marketing offers.
• SMS/Text Messaging:
  • Message Frequency: Varies based on your needs and property interest.
  • Message & Data Rates: May apply, depending on your mobile carrier.
  • Opt-Out: You may opt-out of receiving SMS messages at any time by replying “STOP” to any text message you receive from us. You may also opt out by contacting us directly (see Section 6). After opting out, you may receive one final text confirming your request.
  • Help: For help or information, reply “HELP” to any text message or contact us directly.
  • No Sharing: We will not share or sell your mobile number or text messaging originator opt-in data and consent to unaffiliated third parties for their independent marketing purposes.
• Email Marketing Opt-Out: You may opt-out of marketing emails by clicking the “Unsubscribe” link found at the bottom of our emails.

6. Contact Information

If you have any questions or concerns about this Privacy Policy or our data practices, please contact our Compliance Officer:

Call It Closed International Realty

Attn: Privacy Compliance

4851 Tamiami Trl N, Ste 200, Naples, FL 34103

Email: privacy@callitclosed.com

Phone: 866-242-564