Realtor Buddy – Privacy Policy

1. Who We Are and Scope of This Policy

Punctum Systems Holdings LLC provides Realtor Buddy as a B2B SaaS platform that real estate professionals, teams, brokerages, and agencies use to manage their workflows, contacts, leads, properties, and related data.

This Privacy Policy applies to:

Our website at realtorbuddy.online;

Your use of the Realtor Buddy web and related interfaces;

Interactions you have with us in connection with the Service (for example, support requests, billing, or sales inquiries).

This Privacy Policy does not replace or modify any separate contracts you may have with us (such as our Terms of Service or a Data Processing Addendum). In the event of a conflict, the terms of those contracts will generally prevail over this Privacy Policy.

2. Information We Collect

We collect different types of information depending on how you interact with us and with the Service.

2.1 Information You Provide Directly

You may provide information to us when you:

Create or manage an account;

Use the Service to manage your business workflows;

Communicate with us (support, sales, billing);

Configure integrations or advanced features.

This includes:

a) Account and Profile Information

Name and contact details (e.g., first and last name, email address, phone number);

Login details and authentication information (e.g., username, password, security and login-related settings);

Role and professional information (e.g., job title, role, agency/brokerage or company name, team membership);

Preferences (e.g., notification settings, language, time zone).

b) Business and Subscription Information

Company or agency details (e.g., business name, address, industry type);

Subscription and plan details (e.g., plan type, status, start and renewal dates);

Billing contact information (e.g., billing name, address, email);

Communications related to your subscription, account, and usage.

c) Customer Content / Business Data

In the course of using the Service, you and your authorized users may upload, submit, or generate various types of data ("Customer Content" or "Business Data"), such as:

Leads, prospects, clients, and contact records;

Property listings, property details, and related documents;

Notes, tasks, reminders, to-dos, and internal comments;

Files and attachments (e.g., contracts, photos, marketing materials);

Messages and communications (e.g., log of interactions, correspondence, comments);

Custom fields, tags, and other CRM data you configure.

You are generally responsible for the accuracy, quality, and legality of the Customer Content you input into the Service.

d) Communications with Us

Records of your communications with us (e.g., support tickets, emails, chat messages, phone call information);

Feedback, surveys, or testimonials you choose to provide.

2.2 Information We Collect Automatically

When you access or use our website or the Service, we automatically collect certain information about your device and usage.

a) Usage and Device Information

Device and browser details (e.g., type of device, operating system, browser type and version);

IP address and approximate location inferred from the IP address (e.g., city, region, country);

Language settings and time zone;

Log data (e.g., pages viewed, features used, timestamps, referrer URLs);

Event data related to your activity in the Service (e.g., logins, searches, record updates, API calls);

Diagnostic and performance information (e.g., error logs, crash reports, and usage metrics).

b) Cookies and Similar Technologies

We use cookies and similar technologies to operate and improve our website and Service. These may include:

Essential cookies – required for core functionality (e.g., authentication, security, load balancing);

Analytics cookies – help us understand how users interact with our website and Service so we can improve them. Website analytics are only enabled after you explicitly consent on the Punctum Systems marketing site, and we operate Google Analytics 4 in consent mode so no analytics cookies are stored until consent is granted;

(Optional) Marketing or retargeting cookies – may be used where applicable to measure or deliver advertising about our services.

For more detail, see Section 12 (Cookies & Similar Technologies) below.

2.3 Information from Third Parties and Integrations

We may receive information about you or your use of the Service from third parties, for example:

Identity or authentication providers used for login (if applicable);

Payment processors used for subscription billing;

Partners or resellers who help market or provide our Service;

Publicly available sources and business data providers (where permitted by law).

If you connect third-party integrations to Realtor Buddy (for example, messaging platforms such as WhatsApp, email or SMS providers, calendars, mapping tools, analytics tools, or other apps), we may receive information from those services, and they may receive information from us, as authorized by you and governed by the third parties' own terms and privacy policies.

3. How We Use Information

We use the information we collect for the following purposes, to the extent permitted by applicable law:

Provide and Operate the Service

Creating and managing user accounts and profiles;

Providing the features and functionality of Realtor Buddy;

Processing transactions, and enabling integrations you choose.

Manage Accounts, Subscriptions, and Billing

Administering subscriptions, renewals, and plan changes;

Processing payments and invoices (via third-party payment processors);

Handling billing-related inquiries and communications;

Preventing abuse of free trials or promotional offers.

Customer Support and Communications

Responding to your questions, requests, and support tickets;

Sending operational or service-related communications (e.g., security alerts, usage notices, policy updates);

Providing onboarding, training, and best-practice guidance when requested.

Security, Fraud Prevention, and Abuse Detection

Authenticating users and managing access and permissions;

Monitoring for and protecting against security incidents, fraud, and abusive or unauthorized use of the Service;

Investigating and mitigating suspected violations of our terms or policies.

Analytics, Improvement, and Product Development

Analyzing usage, performance, and trends to understand how our Service is used;

Improving existing features and developing new features or services;

Measuring and enhancing the effectiveness of our website, Service, and user experience.

Marketing and Relationship Management (Where Permitted)

Sending you information about new features, updates, and offers relating to our services, in accordance with applicable marketing and consent requirements;

Managing our relationship with you, such as newsletters or product announcements you opt in to receive;

Allowing you to manage your marketing preferences at any time.

Compliance with Legal Obligations and Enforcement of Terms

Complying with applicable laws, regulations, and legal processes;

Responding to lawful requests from law enforcement, regulators, or other authorities;

Enforcing our contracts, terms of service, and protecting our rights, property, and safety, and those of our users or others.

4. Legal Bases for Processing (Where Applicable)

Because Realtor Buddy serves customers globally, the legal basis for processing your personal data can vary depending on your location and applicable law (for example, the EU/EEA General Data Protection Regulation ("GDPR") or similar frameworks).

Where such laws apply, we typically rely on the following legal bases:

Performance of a Contract We process personal data where it is necessary to enter into or fulfill our contract with you (for example, to provide and maintain your account, deliver the Service, and handle billing and support).

Legitimate Interests We process personal data for our legitimate business interests, such as:

Operating, improving, and securing the Service;

Understanding usage patterns and developing new features;

Preventing fraud and abuse;

Communicating with you about the Service (non-marketing, operational communications). We only rely on this basis where our interests are not overridden by your fundamental rights and freedoms.

Consent In some cases, we may rely on your consent, for example:

Placing or reading certain non-essential cookies or using similar technologies;

Sending you certain marketing communications where consent is required by law;

Accessing or using data from optional integrations you have explicitly enabled. You may withdraw your consent at any time, as described in Section 11 (Your Rights & Choices), without affecting the lawfulness of processing based on consent before its withdrawal.

Compliance with Legal Obligations We process personal data where necessary to comply with legal obligations (for example, tax and accounting requirements, responding to lawful requests from authorities, and complying with record-keeping duties).

If you have questions about the specific legal basis we rely on for any particular processing activity, you may contact us using the details in Section 17 (Contact Us).

5. How We Share Information

We share information as described below, to the extent permitted by applicable law. We do not share personal data in ways that are inconsistent with this Privacy Policy.

5.1 Service Providers and Subprocessors

We use trusted service providers (sometimes called subprocessors in data protection laws) to help us operate, secure, and improve our website and Service. These may include:

Cloud hosting and infrastructure providers;

Database and storage providers;

Email delivery, notification, and communications tools;

Logging, monitoring, performance, and analytics providers;

Customer support and helpdesk systems;

Payment processors and billing platforms.

These service providers are authorized to use your personal data only as necessary to provide services to us and are subject to contractual obligations to protect your information.

5.2 Third-Party Integrations Chosen by You

If you enable or connect third-party integrations within Realtor Buddy (for example, WhatsApp, email or SMS providers, calendars, mapping tools, analytics, or other apps), we may share information with those third parties or receive information from them, as necessary to enable the integration.

The collection, use, and disclosure of data by these third parties is governed by their own terms and privacy policies, not this Privacy Policy. You are responsible for reviewing and managing your settings with those third parties.

5.3 Professional Advisors

We may share information with our professional advisors, such as lawyers, auditors, accountants, and financial or security consultants, where necessary for the purposes of obtaining their professional services and only under appropriate confidentiality obligations.

5.4 Legal and Safety Reasons

We may disclose information, including personal data, when we believe in good faith that such disclosure is reasonably necessary to:

Comply with any applicable law, regulation, legal process, or governmental request;

Enforce our agreements, terms of service, and other legal rights;

Protect the rights, property, or safety of Punctum, our users, or the public;

Detect, prevent, or address security or technical issues, fraud, or abuse.

5.5 Business Transfers

If we are involved in or considering a merger, acquisition, financing, reorganization, sale of assets, or similar transaction, your information may be disclosed to and transferred as part of that transaction, subject to appropriate confidentiality obligations. Any successor entity will be subject to the same or materially similar privacy commitments that apply under this Privacy Policy, unless you are notified otherwise and given any applicable choices.

5.6 No "Sale" of Personal Data

Punctum does not sell personal data in the sense that term is commonly used in privacy laws. We also do not share personal data for cross-context behavioral advertising in a manner that would constitute a "sale" under such laws.

6. International Data Transfers

Punctum and many of our service providers are located in the United States and may process data in the U.S. and other countries. As a result, your personal data may be transferred to and processed in countries that may have different data protection laws than those in your country of residence, and in some cases may be less protective.

Where required by law (for example, for data from the European Economic Area (EEA) or Switzerland), we implement appropriate safeguards to protect your personal data during such transfers, which may include:

Relying on Standard Contractual Clauses (SCCs) or similar approved contractual mechanisms;

Implementing additional technical and organizational measures to protect the data;

Other safeguards as recognized under applicable data protection laws.

If you would like more information about international transfers or the safeguards we use, you may contact us as described in Section 17 (Contact Us).

7. Data Retention

We retain personal data for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including:

To provide and support the Service;

To comply with legal, tax, or accounting obligations;

To resolve disputes and enforce agreements.

In general:

Account and profile data are retained for as long as your account is active and for a reasonable period thereafter, to maintain records, resolve disputes, and comply with legal obligations.

Customer Content / Business Data are retained for the duration of your subscription and for a limited period after termination or cancellation (for example, to allow final exports or backups), after which we may delete or anonymize such data, subject to our backup and archival policies and any legal obligations.

Usage and technical logs are retained for a limited period for security, diagnostics, and analytics purposes.

Customers can typically access and export their Business Data while the subscription is active, and for a limited period after termination, subject to technical feasibility and legal or contractual restrictions. After the applicable retention periods, we will delete or anonymize personal data in accordance with our data retention policies and applicable law.

8. Security

We take reasonable technical and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures may include:

Encryption of data in transit using industry-standard protocols (e.g., TLS/HTTPS);

Access controls and authentication mechanisms to restrict access to authorized personnel only;

Segregation of customer environments in a multi-tenant architecture;

Logging, monitoring, and alerting for suspicious activities;

Regular updates, maintenance, and security reviews of our systems;

Internal policies and training regarding data protection and security.

However, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect your personal data, we cannot guarantee absolute security.

If you believe your account or data may have been compromised, please contact us immediately using the details in Section 17 (Contact Us).

9. Roles & Responsibilities: Controller vs. Processor / Service Provider

Depending on the type of data and your relationship with us, Punctum may act as a "Controller" (or "business") or a "Processor" (or "service provider") under applicable data protection laws.

9.1 Where Punctum Acts as Controller

Punctum generally acts as a Controller for:

Account and profile information for users of the Service;

Subscription and billing information (excluding full payment card data, which is processed by our payment processor);

Website usage data, service usage analytics, and logs;

Communications you send directly to us (e.g., support requests, sales, or marketing sign-ups).

As a Controller, we determine the purposes and means of processing this personal data, as described in this Privacy Policy.

9.2 Where Punctum Acts as Processor / Service Provider

For Customer Content / Business Data that you and your users input into Realtor Buddy (e.g., leads, contacts, properties, notes, messages), Punctum generally acts as a Processor / Service Provider on behalf of our business customers (such as agencies, brokerages, and real estate organizations).

In this role:

Our customers are typically the Controller of such data;

We process Customer Content only in accordance with our contracts with the customer and their documented instructions, including any applicable Data Processing Addendum;

We do not use Customer Content for our own independent purposes beyond providing and improving the Service, security, and other limited internal uses consistent with our processor role and applicable law.

9.3 Data Processing Addendum (DPA)

For business customers that require it, a Data Processing Addendum (DPA) is available on request, which further governs our processing of personal data as a Processor. The DPA works together with this Privacy Policy, but is a separate legal document that prevails in case of conflict with respect to processing activities covered by the DPA.

10. If You Are an End Customer or Lead of a Realtor Buddy User

Realtor Buddy is typically used by real estate professionals, agencies, teams, and brokerages to manage their relationships with leads, prospects, and clients.

If your personal data appears in the Realtor Buddy platform (for example, as a lead, prospect, or client of a real estate professional):

The relevant real estate professional, agency, brokerage, or other business using Realtor Buddy is usually the Controller of your data;

Punctum processes your data on behalf of that business as a Processor / Service Provider;

This means that your primary point of contact for privacy questions or rights requests (e.g., access, correction, deletion) is the business that collected your data and entered it into Realtor Buddy.

Where required by law (for example, under GDPR or similar laws), Punctum will assist our business customers in responding to requests from individuals relating to their personal data, in line with our role as a Processor and our contractual obligations.

If you contact us directly about data that we process solely on behalf of one of our business customers, we may:

Refer your request to the relevant customer (Controller); and/or

Inform you how to contact the business that controls your data.

11. Your Rights & Choices

Depending on your location and the applicable data protection laws, you may have certain rights in relation to your personal data.

11.1 Rights Where Punctum Is Controller

Where Punctum acts as Controller of your personal data (for example, account, billing, or website usage data), and subject to applicable law, you may have rights to:

Access: Request confirmation of whether we process your personal data and receive a copy of that data.

Rectification: Request that we correct or update inaccurate or incomplete personal data.

Erasure: Request that we delete your personal data in certain circumstances (also known as the "right to be forgotten").

Restriction: Request that we restrict processing of your personal data in certain circumstances.

Portability: Request a copy of the personal data you have provided to us in a structured, commonly used, and machine-readable format, and to have that data transmitted to another controller where technically feasible.

Objection: Object to certain types of processing, including where we rely on legitimate interests (for example, for direct marketing purposes).

Withdraw Consent: Where we rely on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

These rights are not absolute and may be subject to limitations and exceptions under applicable law.

11.2 Exercising Your Rights

You can often update or correct certain account information directly within the Service. Where this is not possible or where you wish to exercise other rights, you may contact us at:

Email: hello@punctum-systems.com

We may need to verify your identity before completing your request, and in some cases we may be unable to fully comply with your request, for example:

Where we must retain certain data for legal, regulatory, security, or business continuity reasons;

Where your request would conflict with another person's rights or our contractual obligations.

We will respond to your request in accordance with applicable law.

11.3 Right to Complain

Depending on your location, you may have the right to lodge a complaint with a data protection authority or similar regulator if you believe we have not complied with applicable data protection laws. We encourage you to contact us first so that we can attempt to address your concerns directly.

12. Cookies & Similar Technologies

Cookies are small text files placed on your device when you visit a website or use an online service. Similar technologies include pixels, tags, local storage, and other tracking mechanisms.

We use cookies and similar technologies for the following purposes:

Essential cookies Necessary for the website and Service to function properly (e.g., login sessions, security protections, load balancing, and navigation).

Analytics cookies Help us understand how visitors and users interact with our website and Service (e.g., pages visited, time spent, features used) so that we can improve performance, usability, and content.

(Optional) Marketing or retargeting cookies May be used, where applicable and permitted, to help us measure the effectiveness of our marketing campaigns and to show you more relevant information about our services.

Managing Cookies

You can manage your cookie preferences in several ways:

Browser controls: Most web browsers allow you to control cookies through their settings, including blocking or deleting cookies. Please refer to your browser's help or settings section for more information.

In-Service or website settings: Where provided, you may have the option to manage certain cookie or tracking preferences via banners, pop-ups, or account settings.

Opt-outs from third-party tools: Some third-party analytics or advertising providers offer their own opt-out mechanisms.

Please note that if you disable or reject certain cookies, some features of our website or Service may not function properly.

13. Children

The Service is not directed to children under the age of 18, and we do not knowingly collect personal data from children under 18 through the Service.

If you are under 18, you should not use the Service or provide personal data to us.

If we become aware that we have collected personal data from a child under 18 without appropriate authorization, we will take reasonable steps to delete that information as soon as possible. If you believe we may have collected such information, please contact us as described in Section 17 (Contact Us).

14. Third-Party Links & Services

Our website or Service may contain links to or integrations with third-party websites, services, or applications that are not operated or controlled by Punctum (for example, messaging platforms, email providers, mapping tools, analytics, or social media).

This Privacy Policy does not apply to those third-party services, and we are not responsible for their privacy or data protection practices. We encourage you to review the privacy policies of any third-party services you access or integrate with Realtor Buddy.

15. Data Processing Addendum (DPA)

For our business customers, Punctum offers a Data Processing Addendum (DPA) that governs our processing of personal data as a Processor / Service Provider on behalf of the customer.

The DPA is available upon request and may form part of your service agreement with us.

The DPA addresses topics such as data subject rights assistance, subprocessors, international transfers, and security measures in more detail.

This Privacy Policy is distinct from, and does not replace, the DPA or our other contractual commitments.

In the event of any conflict between this Privacy Policy and a DPA with respect to personal data that we process as a Processor on behalf of a customer, the terms of the DPA will generally prevail.

16. 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 "Effective Date" at the top of this Privacy Policy;

We will post the updated Privacy Policy on Realtorbuddy.online;

For material changes that significantly affect your rights or how we process personal data, we will provide additional notice as appropriate (for example, by email, via the Service, or through a prominent notice on our website), where required by applicable law.

Your continued use of the website or Service after the updated Privacy Policy becomes effective will signify that you have read and understood the changes, to the extent permitted by law.

17. Contact Us

If you have any questions or concerns about this Privacy Policy, our data practices, or if you wish to exercise your rights, you may contact us at:

Punctum Systems Holdings LLC 1209 Mountain Road PL NE, STE R, Albuquerque, NM 87110, USA

Email: hello@punctum-systems.com

We will do our best to respond to your inquiry in a timely and appropriate manner, in accordance with applicable law.