Privacy Policy

1. Who we are and what this policy covers

APG Technology, LLC, a Georgia limited liability company ("APG Technology," "we," "us," or "our"), provides the Relite customer-relationship-management platform at relitecrm.com and the website at reliteai.com (together, the "Service"). This Privacy Policy describes our practices for personal information we handle through the Service and our websites. It should be read together with our Terms of Use.

This policy does not govern the independent privacy practices of our customers (the real estate professionals who use the Service) toward their own clients and leads, or of any third-party websites or services we link to or integrate with.

2. Our two roles: account data vs. your Contacts' data

The Service involves personal information in two different ways, and our role differs for each:

• Account and profile information about you, our customer and your Authorized Users. For this information we act as the party that decides how and why it is processed (a "controller" or "business").
• Contact and lead information that you, our customer, load into or generate in the Service about your clients, leads, and prospects ("Contacts"). For this information we act as a service provider / processor: we handle it on your behalf and at your direction, to provide the Service to you. You decide what Contact information to collect and how to use it, and you are responsible for providing notices to your Contacts and honoring their privacy rights. If you are a Contact and want to exercise rights over your information, please contact the real estate professional who holds your information; we will support them in responding.

3. Information we collect

Information you provide directly:

• Account registration — your name, email address, and password (stored only in salted, hashed form by our authentication provider).
• Business profile — information you add in Settings, such as your business or sender name, brokerage/organization, physical address, phone number, website, logo, and licensing and membership details (for example, real estate board membership, state license number, MLS office code, and firm license number).
• Customer Content — the information you enter or upload about your Contacts and your business, including Contact names, email addresses, phone numbers, mailing addresses, lead types and sources, buyer/seller preferences, notes, subscription status, activities, valuations, and showings; property listings; offers; business expenses (and any receipts or documents you attach); commissions; and marketing content.
• Communications — messages you send to us (for example, support requests) and your responses to surveys or emails.
• Payment information — if you purchase a paid plan, your payment details are collected and processed by our third-party payment processor, Stripe, Inc.. We do not store full payment card numbers; we receive limited billing information such as your plan, billing contact, and transaction status.

Information we collect automatically:

• Usage and device data — such as IP address, browser type, device and operating-system information, pages and features used, and dates and times of access, collected through server logs and our hosting providers.
• Cookies and similar technologies — we use strictly necessary cookies to authenticate your session and keep you signed in, and to maintain security. We do not use the Service to serve third-party advertising, and we do not use advertising or cross-site tracking cookies in the application. See Section 4.

Information from third parties:

• Lead-capture integrations — if you connect a lead source such as your Luxury Presence website, we receive the Contact and inquiry information that source sends to the Service so it can create and update your leads.

We do not intentionally collect special categories of sensitive personal information through the Service, and you should not store such information in free-text fields unless you have a lawful basis and have obtained any required consent from your Contacts.

4. Cookies and tracking

We use only cookies and local storage that are necessary to deliver the Service — principally a secure, HTTP-only session cookie that keeps you authenticated. Because these are strictly necessary for the Service to function, they are set when you sign in. We do not use third-party advertising or analytics-for-advertising cookies within the application. Your browser can be set to refuse cookies, but the Service will not work properly without the session cookie.

5. How we use information

We use personal information to:

• provide, operate, maintain, and secure the Service and your Account;
• authenticate users and protect against fraud, abuse, and unauthorized access;
• process subscriptions, billing, and renewals;
• respond to your requests and provide customer support;
• send you administrative and transactional messages about the Service (for example, security alerts, billing notices, and changes to our terms or policies);
• send, at your direction, the email communications you create for your Contacts, and handle unsubscribe requests;
• monitor and improve the Service, including through aggregated or de-identified analytics; and
• comply with law and enforce our Terms of Use.

We process your Contacts' information only to provide the Service to you and as you instruct, not for our own independent purposes.

6. How we share information

We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We disclose personal information only as follows:

• Service providers (subprocessors). We use trusted vendors to run the Service. They may process personal information only to perform services for us, under contracts that require appropriate confidentiality and security:

• At your direction. When you send communications or share data through a feature of the Service, we transmit it as you instruct (for example, sending your newsletter to the recipients you select).
• Legal and safety. We may disclose information if required by law, subpoena, or legal process, or where we believe in good faith it is necessary to comply with law, protect our or others' rights, safety, or property, or enforce our agreements.
• Business transfers. If we are involved in a merger, acquisition, financing, or sale of assets, personal information may be transferred as part of that transaction; we will require the recipient to honor this policy or provide notice of any material change.
• Aggregated or de-identified data. We may share information that does not identify any individual.

7. Email communications and your choices

From us. We send transactional and administrative emails necessary to operate your Account; you cannot opt out of these while you have an Account. If we send optional product or marketing emails, you may opt out using the unsubscribe link or by contacting us.

From you to your Contacts. When you use the Service to send newsletters or marketing emails to your Contacts, you are the sender. The Service is designed to support compliance with the federal CAN-SPAM Act — including a functioning unsubscribe mechanism and the ability to include your physical postal address — but you are responsible for the content of your messages, for having a lawful basis to contact each recipient, and for promptly honoring opt-outs. See Section 8 of the Terms of Use.

8. Data retention

We retain account and Customer Content for as long as your Account is active and as needed to provide the Service. After your subscription ends, we retain Customer Content for a limited wind-down period (see Section 16 of the Terms of Use) and then delete or de-identify it in the ordinary course, unless a longer period is required to comply with law, resolve disputes, or enforce our agreements. You can delete most Customer Content yourself within the Service at any time.

9. How we protect information

We maintain administrative, technical, and organizational safeguards designed to protect personal information, including encryption of data in transit and at rest through our hosting providers, row-level access controls that isolate each Organization's data, authenticated access, and the principle of least privilege for internal access. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for safeguarding your login credentials and for configuring access for your Authorized Users appropriately.

10. Data breach notification

If we become aware of a breach of security leading to the unauthorized acquisition of personal information, we will investigate and will notify affected individuals and any applicable authorities as required by law, including Georgia's breach-notification statute (O.C.G.A. § 10-1-910 et seq.) and any other applicable state law. Where we act as a service provider to you, we will notify you without undue delay so that you can meet your own notification obligations to your Contacts.

11. Your choices and rights

You can access and update most of your account and business information, and much of your Customer Content, directly in the Service. You may also:

• Access or correct your account information by contacting us;
• Delete your Account and associated data by contacting us (subject to the retention rules in Section 8 and any legal obligations); and
• Opt out of any optional marketing emails from us.

A note on Georgia law. As of the "Last updated" date of this policy, the State of Georgia has not enacted a comprehensive consumer data-privacy law granting residents a defined set of access, deletion, and opt-out rights. Georgia law that does apply to our handling of personal information includes the Georgia Fair Business Practices Act (O.C.G.A. § 10-1-390 et seq.), which prohibits unfair and deceptive practices, and the breach-notification statute referenced in Section 10. We honor the choices described above regardless, and will update this policy if Georgia enacts a comprehensive privacy law.

12. California privacy rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the "CCPA"), gives you certain rights regarding your personal information. This section applies to personal information we handle as a "business" — principally the account and profile information of California customers and website visitors. For Contact information we handle on behalf of our customers, we act as a "service provider," and a California resident who is a Contact should direct requests to the real estate professional who holds their information.

Categories we collect. In the preceding 12 months, we have collected the following CCPA categories of personal information: identifiers (such as name, email address, and IP address); customer records and commercial information (such as business and billing details and subscription history); internet or network activity (such as usage and log data); and the contents of communications you send us. We collect these from you directly, automatically through your use of the Service, and from service providers and integrations you connect.

Purposes. We use these categories for the business purposes described in Section 5.

Disclosure. In the preceding 12 months, we have disclosed identifiers, customer-records, commercial, and internet-activity information to the service providers listed in Section 6 for business purposes.

No sale or sharing. We do not sell personal information, and we do not share it for cross-context behavioral advertising, as those terms are defined under the CCPA. We also do not knowingly sell or share the personal information of consumers under 16.

Your California rights. Subject to verification and legal limits, you have the right to:

• Know / access the categories and specific pieces of personal information we have collected about you, the sources, the purposes, and the categories of recipients;
• Delete personal information we have collected from you;
• Correct inaccurate personal information;
• Opt out of the sale or sharing of personal information (note: we do not sell or share it); and
• Limit the use of sensitive personal information (note: we do not use sensitive personal information for purposes that trigger this right).

We will not discriminate against you for exercising these rights.

How to exercise. Submit a request by emailing contact@goapgtech.com with "California Privacy Request" in the subject line. We will verify your request by confirming information we already hold about you. You may use an authorized agent to make a request on your behalf, with proof of authorization. We will respond within the timeframes the CCPA requires.

Shine the Light. California's "Shine the Light" law permits California residents to request information about disclosures of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing.

13. Children's privacy

The Service is a business tool and is not directed to children. We do not knowingly collect personal information from children under 13 (or under 16 where applicable). If you believe a child has provided us personal information, contact us and we will delete it. You are responsible for not entering information about children into the Service without a lawful basis.

14. Where information is processed

We operate in the United States, and personal information we handle is processed and stored in the United States. If you access the Service from outside the United States, you understand that your information will be processed in the United States, where data-protection laws may differ from those in your location.

15. Changes to this policy

We may update this Privacy Policy from time to time. If we make a material change, we will update the "Last updated" date and, where appropriate, provide additional notice through the Service or by email. Your continued use of the Service after a change takes effect means you accept the updated policy.

16. Contact us

For privacy questions or requests, contact:

APG Technology, LLC
2101 Reynolds Walk Trl, Greensboro, Georgia 30642
Email: contact@goapgtech.com