Privacy Policy

1.1 Interpretation

Words with initial capital letters have the meanings defined below. These definitions apply equally in singular and plural form.

1.2 Definitions

This Privacy Policy applies to three distinct categories of users:

Consumers who visit the Service to search for and contact real estate agents. Consumers do not create accounts and are not required to submit personal information beyond what they voluntarily provide in contact forms.

Applicants who submit a membership application through the /join page. Applicants provide personal and professional information for the purpose of membership consideration.

Members who have been approved and have purchased an active Subscription. Members have accounts, public profiles, and access to the Member Portal. Member data is processed more extensively than Consumer or Applicant data.

3.1 Information You Provide Directly

From Consumers:

• Name, email address, and phone number submitted through contact forms on Agent profile pages or the agent directory
• Message content submitted through contact forms
• Stated intent (buying, selling, or other) submitted through contact forms

From Applicants:

• Full name, email address, phone number
• Brokerage or firm name
• Office or work address
• Geographic market selection
• Years of licensed experience
• Specialty areas
• Real estate license number and state of licensure
• License type (salesperson, broker, broker-associate, or equivalent)
• Optional personal message included with the application

From Members:

All information collected from Applicants, plus:

• Member Portal login credentials (email address and authentication token)
• Professional biography
• Headshot photograph
• Website URL
• LinkedIn and Instagram profile URLs
• Languages spoken
• Awards and professional recognitions
• Public-facing contact email address, which may differ from login email
• Testimonials and client reviews submitted for display on the Public Profile
• Any additional content voluntarily submitted for publication on the Service including guest blog posts

3.2 Payment Information

All payment transactions are processed directly by Stripe, Inc. We do not collect, store, or have access to your full credit card number, CVV, or bank account details. When you complete a purchase through our Service, you are submitting your payment information directly to Stripe's secure payment interface, which is governed by Stripe's own privacy policy available at https://stripe.com/privacy.

We receive from Stripe only the following limited data: a customer identifier, a subscription identifier, subscription status, renewal date, and the last four digits of the card on file. This information is stored in our database solely for the purpose of managing your membership status and renewal notifications.

3.3 Real Estate License Information

As part of the application and membership process, we collect your real estate license number, issuing state, license type, and license status. This information is used to verify that applicants are licensed to practice real estate in the United States and to maintain accurate membership records. License information is not displayed publicly on the Service unless you expressly choose to include it in your Public Profile bio.

3.4 Automatically Collected Usage Data

When you access the Service, we automatically collect:

• IP address
• Browser type and version
• Operating system
• Pages visited and time spent on each page
• Referring URL
• Device type and screen resolution
• Date and time of each request
• Geographic location derived from IP address at city and country level only

3.5 Location Data

When you use the location-based search feature on the Service, we use the Google Places API to process your city or zip code input. This search is processed through Google's servers and is subject to Google's Privacy Policy at https://policies.google.com/privacy. We do not store your search queries beyond the current session.

3.6 Cookies and Tracking Technologies

We use the following types of cookies:

Strictly Necessary Cookies — Required for the Service to function. These include authentication cookies that keep Members logged into the Member Portal and session cookies that maintain your state as you navigate the site. You cannot opt out of these without losing access to protected features.

Functional Cookies — Used to remember your preferences such as recently viewed agents or search filters. These persist across sessions but do not track you across other websites.

Analytics Cookies — Used to understand how visitors interact with the Service in aggregate. This data is used to improve the Service and is not tied to individual identities.

Advertising and Targeting Cookies — We or our advertising and marketing service providers may use cookies or similar tracking technologies to deliver targeted advertisements to you on third-party platforms based on your activity on the Service. You may opt out of targeted advertising as described in Section 10.

Preference Cookies — Used to store your cookie consent preferences.

You may manage cookie preferences through your browser settings or through the cookie consent banner displayed on your first visit. Disabling non-essential cookies will not affect your ability to browse the public portions of the Service but may affect Member Portal functionality.

4.1 To Operate the Service

We use your information to:

• Display active Member profiles on the public directory
• Process and evaluate membership applications
• Create and maintain Member accounts
• Operate the Member Portal and associated features
• Deliver contact form submissions to the relevant Agent's email address
• Process and manage Subscription payments through Stripe
• Maintain accurate seat counts per market

4.2 To Communicate With You

We use your information to:

• Send application confirmation and status notifications
• Deliver membership approval communications and payment links
• Send payment confirmation and welcome emails upon Subscription activation
• Send renewal reminder emails 30 days prior to Subscription renewal date
• Send payment failure notifications with instructions to update billing information
• Forward agent-to-consumer contact form messages to the relevant Agent
• Respond to support inquiries submitted through the contact page
• Send service-related announcements that are a necessary part of the Service

4.3 For Marketing and Promotional Purposes

With your consent or where otherwise permitted by applicable law, we use your information to:

• Send promotional communications about the Service, membership benefits, and special offers
• Feature Member names, photographs, and professional information in our marketing materials including social media posts, email campaigns, advertising, and press releases
• Publish Member Welcome Announcements on our Facebook, Instagram, Twitter, and LinkedIn channels upon joining
• Solicit and publish Member testimonials and reviews on the Service and in marketing materials
• Include Member information in printed publications and digital media where we promote the Elite 100 Agents program
• Conduct customer feedback collection for the purpose of evaluating and improving the Service

You may opt out of marketing communications at any time as described in Section 10. Opting out of marketing communications does not affect transactional communications necessary to operate the Service.

4.4 For Targeted Advertising

We may use Personal Data and Usage Data, directly or through authorized Service Providers, to deliver targeted advertising to you and to audiences with similar characteristics on third-party platforms including social media networks and advertising networks. This may involve profiling based on your activity on the Service. You have the right to opt out of this profiling as described in Section 10.

4.5 For Testimonials and Customer Feedback

We may request testimonials or reviews from Members and, with their consent, publish those testimonials on the Service, in marketing materials, in press releases, and across our social media channels. If you submit a testimonial, you grant the Company a perpetual, worldwide, royalty-free license to use, reproduce, and distribute that testimonial in connection with the promotion of the Service. You may request removal of your testimonial at any time by contacting us.

4.6 For Fraud Prevention and Security

We use IP addresses, submission timestamps, and usage patterns to detect and prevent spam, abuse, and fraudulent submissions. Contact form submissions are rate-limited and logged for this purpose. This data is retained for a period of 12 months.

4.7 For Administration and Legal Compliance

We use your information to maintain internal business records, manage customer orders and membership accounts, resolve disputes, enforce our Terms of Service and this Privacy Policy, comply with applicable laws and regulations, and respond to legal process.

4.8 To Improve the Service

We use aggregated and anonymized usage data to analyze how the Service is used, identify technical issues, measure the effectiveness of features, and make improvements to the platform.

5.1 Consent to Public Listing

By purchasing a Membership Subscription, each Member expressly consents to the publication of their Public Profile on the Service. The Public Profile is visible to all visitors without requiring any login. Information displayed may include: full name, headshot photograph, professional biography, brokerage or firm name, professional title, specialty areas, office address, Google Maps location embed, phone number, public email address, website URL, and social media links.

5.2 Consent to Publication in Marketing Materials

By purchasing a Membership Subscription, each Member expressly consents to the use of their name, photograph, firm affiliation, market location, and membership year in the Company's marketing and promotional materials, including but not limited to: social media posts across all platforms operated by the Company, email marketing campaigns, press releases, digital and print advertisements, and the Service itself.

5.3 Consent to Social Media Announcements

Upon joining, the Company will publish a Member Welcome Announcement across its official Facebook, Instagram, Twitter, and LinkedIn channels. By purchasing a Membership Subscription, each Member expressly consents to this announcement and to being tagged or mentioned in such posts. Members may request that a specific announcement be removed by contacting us, but removal of the announcement does not constitute withdrawal of consent to the overall membership or Public Profile.

5.4 Member Responsibility for Profile Content

Each Member is solely responsible for the accuracy and appropriateness of all content submitted for their Public Profile. The Company does not independently verify the accuracy of profile information. By submitting profile content, each Member represents and warrants that the content is accurate, does not infringe any third-party intellectual property rights, and does not violate any applicable law or professional ethics rule.

5.5 Profile Updates and Removal

Members may update their Public Profile at any time through the Member Portal. Upon cancellation or expiration of a Subscription, the Public Profile will be removed from the public directory within 24 hours. The Company retains the right to maintain certain non-public records related to the former membership for legal and administrative purposes as described in Section 8.

5.6 Search Engine Indexing

Public Profile pages are designed to be indexed by search engines including Google, Bing, and others. By consenting to a Public Profile, Members acknowledge that their profile information may be indexed and cached by third-party search engines. Removal of a Public Profile from the Service does not guarantee immediate removal from search engine caches.

6.1 How Contact Data Is Used

When a Consumer submits a contact form addressed to an Agent, the submission including the Consumer's name, email address, phone number if provided, message content, and stated intent is transmitted directly to the Agent's designated contact email address via our email delivery provider. The Company retains a log of contact submissions including sender email, recipient Agent identifier, sender IP address, and submission timestamp for a period of 12 months for fraud prevention and abuse monitoring purposes.

6.2 Company Is Not a Party to Communications

The Company facilitates the delivery of contact form messages but is not a party to any subsequent communication between Consumers and Agents. The Company is not responsible for the content of those communications or for any transaction, agreement, or dispute that arises from them.

6.3 No Guarantee of Response

Submission of a contact form does not guarantee a response from the Agent. The Company does not monitor, screen, or guarantee the responsiveness of its Members.

7.1 Service Providers

We share data with the following Service Providers who process data on our behalf under data processing agreements:

Stripe, Inc. — Payment processing and subscription management. Data shared includes name, email address, and billing address. Stripe processes payment card data directly and independently. Privacy policy: https://stripe.com/privacy.

Google LLC — Maps JavaScript API, Places API, and Geocoding API for location-based search and Agent profile map embeds. Privacy policy: https://policies.google.com/privacy.

Supabase, Inc. — Database hosting, file storage, and authentication infrastructure. All Member, Applicant, and Consumer data collected through the Service is stored on Supabase-managed servers hosted on Amazon Web Services infrastructure in the United States. Privacy policy: https://supabase.com/privacy.

7.2 Advertising and Marketing Agencies

We may share Usage Data, device identifiers, and aggregated audience data with third-party advertising platforms and marketing agencies for the purpose of delivering targeted advertisements and measuring campaign effectiveness. This sharing is conducted in accordance with applicable law and subject to your opt-out rights described in Section 10.

7.3 Analytics Providers

We may share Usage Data with analytics service providers to help us understand how the Service is used, measure traffic patterns, and improve platform performance. Analytics data is shared in aggregated or pseudonymized form where possible.

7.4 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of the Company's assets, your Personal Data may be transferred to the acquiring entity. We will provide notice before your Personal Data is transferred and becomes subject to a different privacy policy.

7.5 Affiliates

We may share your information with affiliated entities under common ownership or control, subject to the terms of this Privacy Policy.

7.6 Legal Requirements

We may disclose your Personal Data when required to do so by law or in response to valid legal process including court orders, subpoenas, or government agency requests. We may also disclose your information to: (1) comply with applicable law or regulation; (2) enforce our Terms of Service or this Privacy Policy; (3) protect and defend the rights or property of the Company; (4) prevent or investigate possible wrongdoing in connection with the Service; (5) protect the personal safety of users of the Service or the public; or (6) protect against legal liability.

7.7 With Your Consent

We may disclose your Personal Data for any additional purpose with your express prior consent.

7.8 What We Do Not Do

We do not sell your Personal Data to data brokers or third parties for their independent commercial use. We do not share your Personal Data with unaffiliated third parties for their own marketing purposes without your consent.

We retain Personal Data for the following periods:

• Consumer contact form data — 12 months from the date of submission, retained for fraud prevention and abuse monitoring purposes.
• Applicant data — Approved applications are retained for the duration of the resulting membership plus 3 years. Rejected applications are retained for 2 years from the date of rejection.
• Member account data — Retained for the duration of active membership plus 5 years following cancellation or expiration, to satisfy legal, tax, and contractual obligations.
• Payment and billing records — Retained for 7 years in accordance with applicable tax and financial recordkeeping requirements.
• Real estate license records — Retained for the duration of the membership plus 3 years for verification and compliance purposes.
• Usage and analytics data — Retained for 24 months in anonymized and aggregated form.
• Security and fraud prevention logs — Retained for 12 months.
• Marketing consents and opt-out records — Retained for the duration of the relationship plus 3 years to demonstrate compliance.

Residual anonymous information and aggregate information that does not identify you directly or indirectly may be stored indefinitely.

We implement commercially reasonable technical and organizational measures to protect your Personal Data against unauthorized access, disclosure, alteration, or destruction. These measures include encrypted data transmission via TLS, encrypted data storage, access controls limiting data access to authorized personnel and service providers, and regular security assessments.

However, no method of data transmission or electronic storage is completely secure. We cannot guarantee absolute security of your data. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify affected individuals and relevant authorities as required by applicable law, and no later than 72 hours after becoming aware of the breach where feasible.

10.1 Access and Correction

You may request access to the Personal Data we hold about you and request correction of any inaccurate data by contacting us at the information provided in Section 16. Members may update most profile information directly through the Member Portal.

10.2 Deletion

You may request deletion of your Personal Data by contacting us. We will honor deletion requests subject to any legal obligations that require us to retain certain data, including financial records, fraud prevention logs, and contractual records. Deletion of your account and data does not entitle you to a refund of any Subscription fees paid.

10.3 Opt-Out of Marketing Communications

All marketing communications include an unsubscribe link. You may opt out of marketing emails at any time by using that link or by contacting us. Opting out of marketing communications will not affect transactional communications related to your membership, including renewal reminders, payment notifications, and service updates.

10.4 Opt-Out of Targeted Advertising and Profiling

You may opt out of targeted advertising and the profiling we carry out for marketing purposes by contacting us at the information provided in Section 16 or by adjusting your cookie preferences through the consent banner on the Service. You may also opt out of interest-based advertising through the Digital Advertising Alliance or the Network Advertising Initiative.

10.5 Do Not Sell or Share My Personal Information

We do not sell your Personal Data as defined under the California Consumer Privacy Act. To the extent that sharing data with advertising or analytics partners for cross-context behavioral advertising constitutes a "sale" or "share" under applicable law, you have the right to opt out of that activity. To submit a Do Not Sell or Share request, contact us at the information provided in Section 16.

10.6 Data Portability

You may request a copy of your Personal Data in a structured, commonly used, machine-readable format by contacting us.

10.7 Do Not Track

Our Service does not currently respond to Do Not Track browser signals. We do not engage in cross-site behavioral tracking beyond what is disclosed in this Privacy Policy.

10.8 California Residents — CCPA and CPRA Rights

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

• The right to know what Personal Data we collect, use, disclose, and share
• The right to delete your Personal Data, subject to certain exceptions
• The right to correct inaccurate Personal Data
• The right to opt out of the sale or sharing of your Personal Data
• The right to limit the use of sensitive Personal Data
• The right to non-discrimination for exercising your privacy rights

To submit a CCPA or CPRA rights request, contact us at the information in Section 16. We will respond within 45 days of receiving a verifiable consumer request, with one possible 45-day extension where reasonably necessary.

10.9 Nevada Residents

Nevada law gives consumers the right to opt out of the sale of certain personal information. We do not sell Personal Data as defined by Nevada law. To submit a request regardless, contact us at the information in Section 16.

10.10 Virginia, Colorado, Connecticut, Texas, and Other State Privacy Laws

Residents of states with applicable consumer privacy laws including Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), and Texas (TDPSA) may have the right to access, correct, delete, and obtain a portable copy of their Personal Data, and the right to opt out of targeted advertising, the sale of Personal Data, and profiling in furtherance of decisions that produce legal or similarly significant effects. Contact us at the information in Section 16 to exercise these rights. We will respond within 45 days.

10.11 European Economic Area and United Kingdom Residents

If you are located in the EEA or UK, you have rights under the GDPR and UK GDPR including the right to access, rectification, erasure, restriction of processing, data portability, and the right to object to processing. Our lawful bases for processing include contract performance, legitimate interests, consent, and legal obligation. To exercise your rights or to lodge a complaint with a supervisory authority, contact us at the information in Section 16.

The Service is intended for use by licensed real estate professionals and adults seeking real estate services. The Service is not directed to individuals under the age of 18. We do not knowingly collect Personal Data from anyone under 18. If you believe we have inadvertently collected data from a minor, please contact us immediately and we will take steps to delete that information.

The Service contains links to third-party websites including agent websites, social media platforms, and professional resources. We are not responsible for the privacy practices of those websites. We encourage you to review the privacy policies of any third-party website you visit.

Elite 100 Agents membership is limited to no more than 100 real estate agents or brokers per defined geographic market under U.S. Provisional Patent #63/386,256. The determination of whether an applicant qualifies for membership is made by the Company based on a review of professional experience, market reputation, and other proprietary criteria. The Company's selection process and criteria are subject to change at the Company's sole discretion.

A nomination or invitation to apply does not guarantee membership. Applicants may not pay a fee solely to be nominated. The membership fee, where applicable, is charged upon approval and acceptance of membership terms.

The designation "Elite 100 Agent" is a membership recognition conferred by Elite 100 Agents, LLC. It does not constitute an endorsement, certification, guarantee, or accreditation by any state real estate commission, the National Association of Realtors, any Multiple Listing Service, or any other governmental or regulatory body. Any references to "elite," "top," or similar terms refer to the Elite 100 Agents membership program only and are not intended to make any representation about any individual member's performance relative to other licensed real estate professionals.

The Company does not independently verify the production volume, transaction history, client reviews, or professional credentials of any Member or Applicant beyond what is submitted through the application process. Consumers are advised to conduct their own due diligence when selecting a real estate agent.

Membership Subscription fees are billed annually. All fees are non-refundable except where required by applicable law. Cancellation of a Subscription stops future billing but does not entitle the Member to a refund of fees already paid. Upon cancellation, the Member's Public Profile will remain active through the end of the current paid membership period and will be removed at expiration.

This Privacy Policy is governed by the laws of the State of Wyoming without regard to its conflict of law provisions. Any dispute arising from this Privacy Policy that cannot be resolved informally through direct communication with us shall be subject to binding individual arbitration administered by the American Arbitration Association under its Consumer Arbitration Rules, conducted in Sheridan County, Wyoming, except that either party may seek injunctive or other equitable relief in a court of competent jurisdiction. You waive any right to bring claims as a class action, collective action, or in any other representative capacity.

For privacy-related inquiries, rights requests, data deletion requests, opt-out requests, concerns about data processing, or to contact our designated data protection representative, please reach out to us through our contact page.

We will acknowledge receipt of your request within 5 business days and respond substantively within 30 days of receipt of a verifiable request, unless a longer period is permitted by applicable law.

We may update this Privacy Policy at any time to reflect changes to our practices, technology, legal requirements, or for other operational reasons. When we make material changes, we will update the "Last Updated" and "Effective Date" fields at the top of this page. For changes that materially affect your rights, we will notify active Members via email at least 30 days before the changes take effect. Your continued use of the Service after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms.