Privacy Policy

1. Introduction

Zovela (“Zovela,” “we,” “our,” or “us”) provides software and related services designed to help real estate professionals identify, prioritize, and act on opportunity signals (the “Services”). This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit our website, complete assessments, create an account, or otherwise interact with the Services.

This Privacy Policy applies to users located in the United States. If you are located outside the United States, please do not use the Services. By accessing or using the Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with this Privacy Policy, you must discontinue use of the Services immediately.

2. Information We Collect

2.1 Information You Provide Directly

We collect information that you voluntarily provide to us when you register for an account, express interest in obtaining information about us or our products and services, participate in activities on the Services, or otherwise contact us. The personal information we collect may include, but is not limited to:

• Identifiers: Name, email address, phone number, mailing address, username, password, and similar contact information.
• Professional Information: Business name, brokerage affiliation, license information, years of experience, market areas served, and team information.
• Commercial Information: Records of products or services purchased, obtained, or considered, including subscription history and transaction records.
• Assessment and Survey Data: Responses to assessments, surveys, questionnaires, and other interactive features of the Services.
• Communications: Records of correspondence with us, including support requests, feedback, and inquiries.
• Payment Information: Billing address and payment card details, which are processed by our third-party payment processors and are not stored on our servers.

You are not required to provide sensitive personal information (such as racial or ethnic origin, religious beliefs, health information, or sexual orientation) to use the Services, and we do not intentionally collect such information.

2.2 Information Collected Automatically

When you access or use the Services, we automatically collect certain information about your device, browsing actions, and usage patterns. This information may include:

• Device Information: Hardware model, operating system and version, unique device identifiers, browser type and version, language preferences, and mobile network information.
• Log Data: Internet Protocol (IP) address, access times and dates, pages viewed, time spent on pages, clickstream data, referring URL, and other actions taken within the Services.
• Location Information: General geographic location inferred from IP address. We do not collect precise geolocation data.
• Cookies and Similar Technologies: Information collected through cookies, pixel tags, web beacons, and similar technologies as described in our Cookie Policy.

2.3 Information from Third-Party Sources

We may receive information about you from third-party sources, including:

• Licensed Data Providers: We obtain information from licensed third-party data providers to enhance, enrich, or contextualize opportunity signals and analytics delivered through the Services. This may include publicly available information, consumer data, and property-related information.
• Public Sources: Information available from public records, government databases, and publicly accessible sources.
• Analytics Partners: Information from analytics providers that helps us understand usage patterns and improve the Services.
• Marketing Partners: Information from marketing and advertising partners to help us reach potential users.

Third-party data is used to generate insights and signals within the platform and is not sold or transferred as standalone datasets. We do not independently verify third-party data for accuracy, completeness, or timeliness, and we make no representations or warranties regarding such data.

3. How We Use Your Information

We use the information we collect for various business and commercial purposes, including:

• Providing and Operating the Services: To create, maintain, and secure your account; to process transactions; to provide customer support; and to deliver the features and functionality of the Services.
• Generating Insights, Assessments, and Recommendations: To analyze data and generate opportunity signals, assessments, analytics, and recommendations through the Services.
• Improving and Developing the Services: To understand how users interact with the Services; to identify trends and usage patterns; to conduct research and analysis; and to develop new products, services, features, and functionality.
• Communications: To send you administrative information, such as updates to our terms and policies; to respond to your comments, questions, and requests; and to provide customer service and support.
• Marketing and Promotional Communications: To send you information about products, services, promotions, events, and other news and information we think may be of interest to you. You may opt out of marketing communications at any time.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent transactions and other illegal activities; to protect the rights and property of Zovela and others; and to enforce our terms and policies.
• Legal Compliance: To comply with applicable laws, regulations, legal processes, or governmental requests.

We do not sell personal information as defined under applicable privacy laws. Zovela provides access to software tools and intelligence derived from a combination of user-provided information and licensed third-party data sources. We do not sell or rent your personal information to third parties for their direct marketing purposes.

4. Automated Processing and Artificial Intelligence

Zovela uses automated systems, machine learning, and artificial intelligence technologies to analyze data, identify patterns, and generate opportunity signals and insights. It is important that you understand the following:

• Informational Outputs Only: All outputs generated by the Services, including opportunity signals, insights, recommendations, and analytics, are provided for informational purposes only. They do not constitute legal, financial, real estate, or other professional advice.
• No Automated Decision-Making: We do not make automated decisions on your behalf that produce legal effects or similarly significant effects concerning you. The Services provide information to assist your decision-making, but all decisions remain yours.
• Human Review and Approval Required: You are responsible for reviewing, verifying, and approving any actions taken based on information provided by the Services. Outputs may be incomplete, delayed, or inaccurate.
• No Training on User Data: We do not use your personal information or user-provided content to train our artificial intelligence or machine learning models. Your data remains your own.
• Responsibility for Use: You are solely responsible for how you use information provided by the Services, including compliance with all applicable laws and regulations governing communications with consumers.

5. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect and store information about your interactions with the Services. Please refer to our Cookie Policy for detailed information about:

• The types of cookies we use and their purposes
• How to manage your cookie preferences
• Third-party analytics and tracking services we use

We honor Global Privacy Control (GPC) signals. If your browser or device transmits a GPC signal, we will treat this as a request to opt out of the sale or sharing of your personal information, as applicable under California law.

6. Sharing of Information

We may share your information in the following circumstances:

• Service Providers: We share information with third-party vendors, consultants, and other service providers who perform services on our behalf, such as hosting, data analytics, payment processing, email delivery, customer service, and marketing. These service providers are contractually obligated to protect your information and use it only for the purposes for which it was disclosed.
• Professional Advisors: We may share information with our lawyers, accountants, auditors, and other professional advisors in connection with the services they provide to us.
• Business Transfers: We may share or transfer information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• Legal Requirements: We may disclose information if required to do so by law or in response to valid requests by public authorities, such as a court order, subpoena, or government investigation.
• Protection of Rights: We may disclose information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service, or as evidence in litigation in which we are involved.
• With Your Consent: We may share information for other purposes with your consent or at your direction.

7. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the information, and applicable legal requirements.

Specific retention periods include:

• Account Information: Retained for the duration of your account and for a reasonable period thereafter to allow for account reactivation or to comply with legal obligations.
• Assessment Results: Retained for as long as your account is active or as needed to provide Services.
• Usage Analytics: Retained in identifiable form for up to 24 months; may be retained indefinitely in aggregated or anonymized form.
• Payment Records: Retained for seven (7) years as required by tax and financial regulations.
• Marketing Preferences: Retained until you withdraw consent or update your preferences.

Aggregated or anonymized data that cannot reasonably be used to identify you may be retained indefinitely for analytics and business purposes.

8. Data Security

We implement appropriate technical and organizational security measures designed to protect the security, confidentiality, and integrity of your personal information. These measures include encryption of data in transit and at rest, access controls, regular security assessments, and employee training on data protection practices.

However, no method of transmission over the Internet or method of electronic storage is completely secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. You are responsible for maintaining the confidentiality of your account credentials and for any activity that occurs under your account.

9. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information. Residents of California and other states with comprehensive privacy laws may have the following rights:

• Right to Know: You have the right to request information about the categories and specific pieces of personal information we have collected about you, the categories of sources from which we collected the information, the business or commercial purposes for collecting the information, and the categories of third parties with whom we share the information.
• Right to Delete: You have the right to request that we delete personal information we have collected from you, subject to certain exceptions.
• Right to Correct: You have the right to request that we correct inaccurate personal information we maintain about you.
• Right to Opt-Out of Sale or Sharing: You have the right to opt out of the sale or sharing of your personal information for cross-context behavioral advertising. As stated above, we do not sell personal information as defined under applicable law.
• Right to Limit Use of Sensitive Personal Information: If we collect sensitive personal information, you have the right to limit its use to purposes necessary to provide the Services.
• Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising any of your privacy rights.

To exercise any of these rights, please contact us at contact@ervl.com. We will verify your identity before processing your request. You may also designate an authorized agent to make a request on your behalf by providing written authorization.

We will respond to verifiable requests within forty-five (45) days of receipt. If we require additional time (up to ninety (90) days total), we will inform you of the reason and extension period in writing.

10. Do Not Sell or Share My Personal Information

Zovela does not sell personal information as defined under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), or other applicable state privacy laws. We do not share personal information for cross-context behavioral advertising purposes.

If you wish to exercise your right to opt out of any future sale or sharing of your personal information, you may do so by contacting us at contact@ervl.com or by using the Global Privacy Control (GPC) signal in your browser.

11. Children's Privacy

The Services are not intended for individuals under the age of eighteen (18). We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us at contact@ervl.com. If we become aware that we have collected personal information from a child under 18 without verification of parental consent, we will take steps to delete that information promptly.

12. Third-Party Links and Services

The Services may contain links to third-party websites, services, or applications that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make changes, we will update the “Last updated” date at the top of this policy. If we make material changes, we may notify you by email (if you have provided one) or by posting a prominent notice on our website prior to the changes becoming effective.

Your continued use of the Services after the effective date of any changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.