Privacy Policy

Updated: March 31, 2025

Introduction

DealTrail is a consulting and marketing partner operated by Michael Ventures LLC, offering real estate professionals (including individual agents, brokerages, teams, and enterprises) a range of services—including strategic consulting, technology implementation, and a software-as-a-service (SaaS) platform for CRM, lead generation, and marketing. While the owner of Michael Ventures LLC holds a California real estate broker license, DealTrail does not operate as a real estate brokerage nor provide legal or brokerage services—our focus is strictly on consulting, marketing, and technology solutions.

We value your privacy and are committed to protecting your personal information. This Privacy Policy describes how DealTrail (“we,” “us,” or “our”) collects, uses, shares, and safeguards personal information when you use our websites, platform, and services (collectively, the “Services”). By accessing or using DealTrail’s Services, you acknowledge and agree to the collection and use of your information in accordance with this Privacy Policy.

We offer our Services through various models, including subscription plans, consulting engagements, affiliate or referral programs, and pay-per-lead arrangements. Regardless of how you interact with DealTrail, we handle personal information in a manner consistent with applicable privacy laws such as the California Consumer Privacy Act (CCPA) and the EU General Data Protection Regulation (GDPR), as well as other relevant data protection standards as of 2025.

Important: Our Services are intended for use by businesses and adults. They are not directed to children under 13, and we do not knowingly collect personal information from anyone under the age of 13. If you are a parent or guardian and believe your child has provided us with personal data, please contact us at [email protected] so we can remove the information.

Scope

This Privacy Policy applies to personal information we collect from:

  • Real estate professional clients who use our CRM and marketing platform or consulting services (“Clients”).

  • Individual consumers who are potential real estate leads or contacts provided to our Clients through our lead generation services (“Leads” or “Consumers”).

  • Visitors to our website or users of our platform and any related tools provided by DealTrail.

If you are using a white-labeled version of our platform provided by one of our Clients under their own brand, please be aware that our Client is responsible for supplying their own privacy policy to you. In such cases, DealTrail acts as a service provider/processor for the Client, and this Privacy Policy describes how DealTrail handles your data on our backend systems. We are not responsible for our Clients’ direct communications or their compliance with laws in the messages they send using our platform. Clients are solely responsible for ensuring that their use of our Services (including any messages they send to Leads via SMS, email, or other channels) complies with all applicable laws (such as anti-spam and telemarketing laws).

Information We Collect

We collect various types of personal information to operate our Services effectively. The types of information we may collect include:

1. Information Provided by Clients - If you are a Client, we collect personal information that you provide when signing up for or using DealTrail:

  • Contact and Identity Information: Your name, business or brokerage name, professional title, email address, phone number, mailing address, and other identifying details. This may include information about your real estate licenses or professional credentials if you provide them.

  • Account Credentials: Username, password, and any security information required to access our platform.

  • Billing Information: Payment details such as credit card information or bank account details (processed securely via our payment processor) and billing address, for subscription fees or pay-per-lead payments.

  • Communications with Us: Records of communications and interactions with DealTrail support or sales (e.g., inquiries, support requests, feedback).

  • Profile and Service Usage Data: Information about your usage of our platform, such as the features you use, campaign settings, and preferences. We may also maintain records of your subscription plan, transaction history, and any consulting or affiliate arrangements associated with your account.

2. Information Related to Leads and Consumers - DealTrail provides lead generation services that supply our Clients with information about potential real estate customers. The personal information we collect and process about individual Leads (Consumers) may come from several sources:

  • Information You Provide to Us: If you are a consumer who interacts with DealTrail directly (for example, by filling out a form on a DealTrail website or landing page to request real estate information), we may collect information such as your name, contact details (phone number, email address), geographic location or address, and details about your real estate interests or preferences (e.g., property type, budget, intent to buy or sell).

  • Client-Provided Lead Data: Our Clients may upload or import their own lists of contacts or Leads into the DealTrail platform. This data is provided by the Client and can include names, contact information, and notes or tags about the individual’s real estate needs or prior interactions. We process this data on behalf of our Clients, and the Client is responsible for having a lawful basis to use and upload this information.

  • DealTrail-Sourced Leads: We may collect consumer data from our own marketing efforts or partnerships. For example, we might run advertising campaigns or affiliate promotions to attract individuals interested in real estate services. If a consumer responds and opts in, we collect their contact information and interest details to pass on as a Lead to our Clients.

  • Third-Party Data Providers: We may obtain lead information from third-party databases or vendors. In such cases, we ensure these vendors are contractually designated as “service providers” under the CCPA, meaning they collect and furnish information to us under strict restrictions on use. These sources might include real estate listing sites, marketing data companies, or public record aggregators that provide contacts of individuals who have expressed interest in real estate opportunities. The typical information we might receive from these sources includes name, contact information, property ownership details, or indications of interest in buying or selling property.

3. Information Collected Automatically - When you visit our website or use our platform, we (or our service providers acting on our behalf) may automatically collect certain technical information about your device and usage of our Services:

  • Usage and Device Information: This includes your IP address, browser type, device type (e.g., desktop or mobile), operating system, referring URLs, and timestamps of visits. We collect this information to understand how our site and platform are used, to monitor and prevent fraud or abuse, and to ensure the security and proper functioning of our Services.

  • Cookies and Similar Technologies: DealTrail uses minimal cookies and similar technologies on our website. Cookies are small text files stored on your browser. We primarily use cookies for essential functionality — such as keeping you logged into your account and remembering your preferences. We do not use cookies for third-party advertising or for tracking your behavior across other sites. For example, we do not use third-party analytics scripts or tracking pixels like the Meta (Facebook) Pixel or Hotjar on our website. We also do not use any AI-driven analytics tools that profile individual behavior. Any analytics we perform are limited to aggregate usage data or necessary debugging information to improve our service performance, and these do not identify any individual.

  • No Third-Party Behavioral Tracking: We do not allow third-party advertisers to set cookies or trackers on our site, and we do not share your browsing behavior with ad networks. Our platform is focused on delivering services to our Clients, not on advertising to consumers via tracking technology.

How We Use Your Information

DealTrail uses personal information for the following purposes:

  • Providing and Improving Services: We use collected information to operate, maintain, and provide all features of our CRM and marketing platform. For Clients, this includes using your information to set up your account, provide you with access to the platform’s tools, and assist you in managing campaigns, leads, and customer relationships. For example, if you upload a contact list, we use that data to enable you to send communications to those contacts as you direct. We also analyze platform usage in aggregate to improve service functionality and user experience.

  • Lead Generation and Distribution: If you are a Lead/Consumer, we use your information to identify and match you with a suitable real estate professional (one of our Clients) who can assist with your real estate needs. This involves packaging your contact information and preferences as a “lead” and providing it to Clients who have subscribed to or purchased our lead generation services. We ensure this process complies with relevant laws (for instance, if required, confirming you consented to be contacted).

  • Communications: We may use contact information (email or phone number) to communicate with you:

    • For Clients: To send account-related communications (e.g., account verification, subscription confirmations, invoices), important service updates, security alerts, and customer support responses. We may also send Clients marketing or promotional communications about DealTrail services, new features, or upcoming events that may interest you. You can opt out of marketing emails at any time by using the unsubscribe link or contacting us.

    • For Leads/Consumers: Generally, DealTrail itself will not directly market to you unrelated to real estate, but we will facilitate communications from our Clients to you if you have been identified as a Lead. Any messages you receive through our platform on behalf of a Client (such as a real estate agent reaching out via SMS or email) are initiated by that Client, not by DealTrail directly. We do, however, handle the technical delivery of those messages and may monitor deliverability (e.g., to ensure messages are sent properly and to process any opt-out requests).

  • Consulting and Affiliate Services: If you engage with us via a consulting arrangement or through an affiliate/referral, we will use your information to fulfill those services. For example, if an affiliate referred you to DealTrail, we may use your information to register you for the service, to compensate the referring affiliate (e.g., confirming that you signed up through their referral), and to manage our relationship with you and the affiliate.

  • Compliance with Legal Obligations: We may process and retain personal information as needed to comply with applicable laws, regulations, and legal processes. For instance, we keep transaction records for tax and accounting requirements, and we may disclose information in response to valid legal requests (such as a court order or a subpoena) or to enforce our agreements and protect our legal rights.

  • Protection and Security: We use information to detect, prevent, or address security issues, fraud, and other malicious or harmful activities. This includes using certain data (like IP addresses or user activity logs) to protect our platform, our Clients, and the Leads from unauthorized access, abuse, or other violations. If we suspect any violation of our Terms of Service or illegal behavior, we may analyze relevant data to investigate and take appropriate action (such as suspending an account or notifying authorities).

  • Internal Business Operations: We might use data for legitimate business interests such as auditing, internal analytics, research and development, troubleshooting, and planning. For example, we may review how Clients use DealTrail to decide what new features to develop or how to improve our user interface. We may also use information to personalize your experience or to provide customer support and training.

We will not use personal information for purposes that are materially different from those described above without obtaining additional consent or providing notice. In particular, we do not use your personal data for any automated decision-making that has legal or similarly significant effects, and we do not engage in profiling for targeted advertising or any purpose not related to our real estate services.

Legal Bases for Processing (GDPR and International Users)

For individuals located in the European Economic Area (EEA), United Kingdom, or other regions with data protection laws, DealTrail’s legal bases for processing your personal information under the GDPR (General Data Protection Regulation) or equivalent laws are as follows:

  • Performance of a Contract: We process personal data to provide our Services in line with our contracts with Clients or with individuals. For example, when a Client signs up, we must process their registration information and payment details to create and administer their account. If you are a Lead who provided your information to be connected with a real estate professional, we process your data to fulfill that service (which can be viewed as performing a contract with you to introduce you to a real estate agent, or with the Client to provide the lead generation service).

  • Legitimate Interests: We may process personal data where it is in our legitimate interests to do so, and those interests are not overridden by your data protection rights. Our legitimate interests include providing and improving our Services, communicating with our Clients, preventing fraud, securing our systems, and running our business efficiently. For example, it is in our legitimate interest to use Clients’ contact information to send them updates about new features or services, or to process limited personal data for internal analytics and service improvement. When relying on legitimate interests, we consider and balance any potential impact on your rights.

  • Consent: In certain cases, we rely on your consent. For instance, if you are a consumer in the EEA who filled out a DealTrail form to request real estate information, we may rely on your consent (obtained when you submitted the form) to process and share your details with a Client. Similarly, if we send marketing communications to an individual in a jurisdiction that requires consent (e.g., certain email marketing under EU law), we will only do so if we have your consent. You have the right to withdraw consent at any time, but this will not affect the lawfulness of any processing already conducted based on consent before its withdrawal.

  • Legal Obligation: Where we have a legal duty to retain or disclose information, we will process personal data to comply with that obligation. For example, we may retain certain records to comply with tax laws or respond to government requests where legally required.

Processing on Behalf of Clients: When DealTrail acts as a processor or service provider for our Clients (for example, when a Client uses our platform to send communications to their own contact list), the Client is responsible for ensuring a valid legal basis for processing that personal data. We process that data only on the Client’s instructions and for the purposes of providing the service to them. If you have questions about why a particular real estate agent (one of our Clients) has your information or is contacting you, please refer to that agent’s own privacy policy or contact them directly, as they are the data controller of the information you provided to them.

Sharing and Disclosure of Information

We understand the importance of keeping your personal information private. DealTrail does not sell or rent your personal information to unrelated third parties for their own marketing purposes. However, in the course of our business, we do share personal data with certain parties, as outlined below:

Sharing Leads with Clients: If you are a Consumer/Lead, the primary instance where we disclose your personal information is to our real estate professional Clients. The core of our lead generation service is to provide your contact information and relevant details to a real estate agent or brokerage that has subscribed to receive leads. We only share your data with Clients who are seeking leads in your area or matching your profile. Once we provide your information to a particular Client, that Client will then be an independent controller of your data (for example, they may input your information into their own CRM or contact management system). We contractually require our Clients to handle the Leads’ information in accordance with applicable privacy laws and this Policy – for instance, they are only allowed to use your data to contact you for their real estate services and are not permitted to resell or misuse your information. (If you are a Client, please see the section “Clients’ Responsibilities for End-User Privacy” below for more details.)

Service Providers (Processors): We share information with trusted third-party vendors who perform services on our behalf, such as:

  • Hosting and Infrastructure: Companies that provide cloud hosting, data storage, and other infrastructure (e.g., data center services) that enable our platform to run and store data securely.

  • Communication Delivery: Services that facilitate the sending of communications, e.g., SMS gateway providers or email delivery services, which we use to send out text messages or emails as directed by our Clients (to their Leads) or for our own service messages.

  • Payment Processors: Secure payment service providers that handle credit card transactions or subscription billing information on our behalf.

  • Analytics and Support Tools: While we do not use invasive analytics, we may use basic analytics or error monitoring tools to maintain and improve the service (these tools might process technical data like IP addresses or device info in the course of providing their service). We may also use customer support software that stores information about support tickets or inquiries.

  • Professional Advisors: Accountants, auditors, lawyers, or similar professionals who are subject to confidentiality and who need access to certain information to advise us or help us comply with obligations.

These service providers are bound by contractual obligations to process personal information only for the purposes specified by DealTrail and to protect it. Under the CCPA, any third party that processes personal data on our behalf is treated as a “service provider” and is not permitted to use the data for their own purposes beyond what is necessary to assist us.

Affiliate and Referral Partners: If you were referred to DealTrail by an affiliate or signed up through a referral link, we may share certain information with the referring partner to the extent needed to honor that referral (for example, confirming that you became a customer so the affiliate can receive credit). This might include your name, business name, and the fact you purchased a certain subscription or service. We do not share sensitive personal information with affiliates, only the minimum details necessary for verification and compensation. Similarly, if we collaborate with another organization (such as a training provider or an industry association) to offer a joint service or promotion, we might share information with them related to that program (e.g., your name and email to coordinate the service). Any partners are required to protect your information and use it only in connection with the program or referral, not for their independent use unless you have a separate relationship with them.

Business Transfers: If DealTrail (Michael Ventures LLC) is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our business/assets, your information may be disclosed to the parties involved and transferred as part of that transaction. In such cases, we will ensure that the recipient of your personal information commits to protect it in a manner consistent with this Privacy Policy. If a change in ownership means your personal data will be used in a materially different way, we will notify you (for example, via an update to this Policy or via email, if appropriate).

Legal Compliance and Protection: We may disclose personal information when we believe in good faith that such disclosure is necessary to:

  • Comply with the law or legal process: This includes responding to subpoenas, court orders, or other legal requests from authorities.

  • Protect rights and safety: We may share information to enforce our Terms of Service or other agreements, or to protect the rights, property, or safety of DealTrail, our employees, our Clients, or others. For example, we might disclose information to law enforcement or consult with relevant authorities if a user is suspected of fraud or an imminent threat.

  • Address security or technical issues: If a security breach or cyber attack occurs, we may share information with experts or law enforcement to help investigate and prevent further harm.

We make sure to limit the personal information we share to only what is necessary for each purpose and ensure appropriate safeguards are in place. Aside from the scenarios above, DealTrail will not share your personal data with third parties without obtaining your consent, unless we have a lawful basis or obligation to do so.

Sale of Personal Information (California Notice)

Under the California Consumer Privacy Act (CCPA), certain disclosures of personal information for monetary or other valuable consideration may be considered a “sale” of information, even if the data isn’t sold in the traditional sense. DealTrail’s core business includes providing real estate lead information to our Clients, and in some cases, our Clients pay on a per-lead basis or as part of a subscription to receive these leads. This transfer of consumer data to a Client for value could be interpreted as a “sale” under California law.

Categories of Personal Information Sold: In the context of providing leads to our Clients, we may sell or share the following categories of personal information about California residents (when applicable):

  • Identifiers: Such as name, email address, telephone number, and mailing address of the Lead.

  • Commercial/Interest Information: Information related to real estate interests, such as whether the individual is looking to buy or sell a home, property preferences, or ownership status.

  • Geolocation Data: General location information of the Lead (for example, city, state, or ZIP code of a property interest or the Lead’s address, if provided).

We do not knowingly sell the personal information of consumers under 16 years of age without the required affirmative authorization (opt-in) as mandated by CCPA (as amended by the CPRA).

Right to Opt-Out of Sale: If you are a California consumer, you have the right to direct us to stop selling your personal information. If you are listed in our database as a potential real estate Lead and you do not want your information shared with our Clients, you can request to opt out of the sale of your personal info. To exercise this right, please contact us at [email protected] with the subject line “Do Not Sell My Personal Information,” or include that request clearly in the body of your email.

Once we receive and verify your opt-out request (we may need to confirm your identity by asking for information such as your name, email, and phone number to match against our records), we will refrain from selling your data to Clients. We will also instruct our service providers to stop any data transfers that could be considered sales on our behalf.

Opting out of sale will not affect your ability to use our website or receive services from us. We do not charge or penalize you for exercising your rights. However, please note that if you are a Consumer who wants to be connected with a real estate professional, opting out of the sale of your info means we will no longer forward your information to any Clients, which could limit any further contact or services via DealTrail.

For clarity, outside of the lead generation context described above, DealTrail does not sell personal information to third parties. Any sharing with third parties (like service providers) is done solely for valid business purposes as described in this Policy, and not for those parties’ independent use.

Data Security

We take the security of personal information seriously. DealTrail implements a variety of administrative, technical, and physical security measures to protect your information from unauthorized access, loss, misuse, or alteration. These measures include:

  • Encryption: We use encryption protocols (such as HTTPS/TLS) to protect data transmitted on our platform. Sensitive information (like payment details) is handled by PCI-compliant processors that encrypt data during transmission and storage.

  • Access Controls: We restrict access to personal data to authorized personnel who need it to perform their job duties. Internal policies and training ensure that employees and contractors understand the importance of confidentiality and privacy.

  • Network & System Security: Our systems are protected by firewalls and monitoring tools to guard against external attacks. We regularly update our software and infrastructure to address security vulnerabilities, and we perform periodic security audits and penetration testing.

  • Data Storage Protections: Personal data is stored on secure servers. We use reputable cloud service providers that employ robust security practices. Backups are performed to prevent data loss, and those backups are secured as well.

  • Incident Response: We have a data breach response plan in place to handle any security incidents swiftly and effectively. This plan includes procedures for notifying affected parties and authorities if required.

Despite our efforts, no method of transmission over the internet or electronic storage is completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee absolute security. In the event of a data breach that compromises the security or confidentiality of personal information, DealTrail will promptly notify affected individuals and relevant regulatory authorities as required by law. We will also take all reasonable steps to mitigate the breach and prevent future occurrences.

Data Retention

DealTrail retains personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Our retention practices are as follows:

  • Client Information: We retain information about our Clients (such as account data, contact details, and billing records) for as long as your account is active and as needed to provide you services. If you cease to be a Client or your subscription ends, we may retain your information for a period of time thereafter. We keep data as needed for legitimate business purposes – for example, to respond to any post-termination inquiries, to maintain records of transactions for financial reporting, to enforce our agreements, or to comply with legal obligations. Typically, basic account records are kept for at least a few years after an account closes, in accordance with statute of limitations and regulatory requirements.

  • Lead/Consumer Information: Lead data that we collect or receive is retained as long as it remains relevant for our lead generation services. If a Lead has been shared with a Client, we may keep a record of that event (for instance, which Client received the information and when). If a consumer opts out of being contacted or requests deletion, we will remove their information from our active lead databases and refrain from sharing it with Clients going forward. We may retain a minimal record (e.g., email or phone number) on a suppression list solely to ensure we honor the no-contact request (so that we don’t inadvertently re-add and contact a person who has opted out).

  • Website Usage Data: Information collected automatically (like server logs, IP addresses, and device information) is generally retained for a short period, typically only as long as necessary for security monitoring, analysis, or service improvement. We may keep aggregated data (which does not identify individuals) indefinitely to analyze trends and performance over time.

  • Communications and Support Records: If you correspond with us (for example, via support emails), we may retain those communications as long as necessary to address your inquiry and for training or quality assurance purposes. We might keep a history of support tickets to better serve recurring issues or to reference past resolutions.

When we no longer have a legitimate business need or legal reason to keep personal information, we will securely delete or anonymize it. If deletion (or anonymization) is not immediately feasible – for example, because the data is stored in a secure backup archive – we will isolate it from further processing until deletion is possible.

International Data Transfers

DealTrail is based in the United States, and the majority of our data processing occurs in the U.S. If you are accessing our Services from outside the United States, please be aware that your personal information will likely be transferred to, stored, and processed in the United States or other jurisdictions where our infrastructure or service providers are located. Data protection laws in these countries may be different from those in your country of residence.

However, when we transfer personal data from the European Economic Area (EEA), United Kingdom, or other regions with data protection laws to a country that hasn’t been deemed to provide an adequate level of protection (such as the United States), we take steps to ensure appropriate safeguards are in place. These safeguards may include:

  • Standard Contractual Clauses: We may implement the European Commission’s Standard Contractual Clauses (SCCs) or similar contractual provisions for data transfer, which obligate the recipient of the personal data to protect it according to EU GDPR standards.

  • Additional Safeguards: We evaluate on a case-by-case basis whether any additional technical and organizational measures are needed. This could involve encryption in transit and at rest, strict access controls, and policies to handle any government data access requests in a manner consistent with privacy rights.

  • Consent and Necessity: In some instances, we may rely on your explicit consent for cross-border transfers (for example, if you as an individual explicitly agree to have your data forwarded to a Client in another country), or the transfer may be necessary to perform a contract with you (e.g., if you are an EU consumer wanting to connect with a U.S. real estate agent, the transfer of your contact info is necessary to provide the requested service).

By using our Services or providing us with your information, you acknowledge that your information will be transferred to and processed in the United States and other countries as described in this Policy. We will handle your information in accordance with this Privacy Policy regardless of where the data is stored or processed.

Do Not Track Signals

“Do Not Track” (DNT) is a privacy preference that users can set in some web browsers to signal that they do not wish to be tracked across different websites. At this time, there is no consistent industry standard or regulation governing how to respond to DNT signals. As a result, many websites, including DealTrail, do not alter their behavior or change services when a DNT signal is received.

We do not track users across third-party websites and do not engage in behavioral advertising, so whether or not you have a DNT signal enabled does not change the experience on our site. We currently do not respond to DNT browser settings or signals. If an industry standard for responding to Do Not Track is established in the future, we will revisit our policy and update this section as needed.

Your Privacy Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal information. DealTrail is committed to honoring the rights of individuals as required by applicable laws such as the GDPR and CCPA (including provisions introduced by the California Privacy Rights Act). These rights include:

  • Right to Access: You have the right to request confirmation of whether we are processing your personal information, and if so, to obtain a copy of the personal information we hold about you. This is sometimes called the right to know what personal information is collected, used, shared, or sold. We will provide you with the requested information in a portable and readily usable format, where required by law.

  • Right to Correction/Rectification: You have the right to request that we correct or update any inaccurate or incomplete personal information we hold about you. Upon verification of the accuracy of the new information, we will correct our records. (California residents gained the right to request correction of inaccurate personal information under the CPRA, effective January 2023, and EU individuals have this right under GDPR.)

  • Right to Deletion: You can request that we delete your personal information. This is sometimes referred to as the “right to be forgotten.” We will delete the information we hold about you, and direct our service providers to do the same, subject to certain exceptions. For example, we may retain data if needed to complete a transaction you requested, detect security incidents, comply with a legal obligation, or other exceptions permitted by law. If an exception applies, we will let you know in our response.

  • Right to Restrict Processing: Where applicable (such as under GDPR), you can ask us to limit or suspend the processing of your personal information under certain circumstances – for instance, if you contest the accuracy of the information or object to our processing, we may restrict use while we consider your request.

  • Right to Object: You have the right to object to our processing of your personal information in certain situations. Under GDPR, you can object when we process data based on legitimate interests or for a task in the public interest, and we will honor your objection unless we have compelling legitimate grounds to continue. You also have an absolute right to object to us using your personal information for direct marketing purposes. For example, if you no longer wish to receive promotional emails from us, you can opt out at any time.

  • Right to Data Portability: You have the right to request a copy of certain personal information in a structured, commonly used, machine-readable format, and to have that information transmitted to another data controller where technically feasible. This right applies to information you provided to us directly and that we process by automated means, under the GDPR.

  • Right to Opt Out of Sale/Sharing: If you are a California resident, you have the right to opt out of the sale of your personal information (as detailed in the “Sale of Personal Information” section above). California law also gives you the right to opt out of the “sharing” of personal information for cross-context behavioral advertising, though as noted, DealTrail does not engage in such sharing. We extend the option to opt out of any non-essential data transfers to all users where practicable. To exercise this right, contact us at [email protected].

  • Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights. In practice, this means we won’t deny you our services, charge you different prices, or provide a different level of service just because you exercised your rights. (Do note that if you request deletion of certain data or opt out of certain uses, it may impact our ability to provide some services – for example, if you opt out of our lead sale and you are a consumer, we can’t connect you with a real estate agent through our platform. But we will not punish you for making the request itself.)

  • Right to Withdraw Consent: If we are processing your personal information based on your consent, you have the right to withdraw that consent at any time. For example, if you consented to receive marketing emails or to be contacted by our Clients and you change your mind, you can withdraw your consent. This will not affect the lawfulness of processing based on consent before its withdrawal.

  • Right to Lodge a Complaint: If you believe we have infringed your privacy rights or violated data protection laws, you may have the right to complain to a data protection authority. For individuals in the EU/EEA, this would be a supervisory authority in the country of your residence or workplace. For example, a UK user can complain to the UK Information Commissioner’s Office (ICO). We would appreciate the opportunity to address your concerns directly, so we encourage you to contact us first at [email protected] so we can try to resolve the issue.

How to Exercise Your Rights: You may contact us at [email protected] to make any privacy-related request. Please clearly state your request (for example, “I am requesting access to my personal information” or “Please delete my personal information”) and provide sufficient information for us to verify your identity. Verification is necessary to ensure we are acting on requests to the correct person’s data – we may ask you to provide or confirm personal details we have on file (such as your name, email, phone number, or last interaction with us). If you are a California resident using an authorized agent to submit a request on your behalf, we will require proof of the agent’s authorization and may still ask you to verify your identity directly with us.

We will respond to your request within the timeframe required by law. Under GDPR, we generally respond within one month, and under CCPA, within 45 days (with the possibility of a 45-day extension in certain cases). There is no fee for making a request, unless it is excessive, repetitive, or manifestly unfounded—in which case, we may charge a reasonable fee or refuse to act on the request (as permitted by law). We will inform you if any fee or refusal is applicable and explain our reasoning.

Keep in mind that these rights are not absolute. In some instances, we may lawfully decline your request if an exemption applies. For example, if you request deletion, but we are required by law to keep certain information (such as tax records), we will retain the necessary information and inform you of that. However, we will not retain personal data beyond what is legally permissible or necessary once a valid deletion request has been received.

Clients’ Responsibilities for End-User Privacy

If you are a Client using DealTrail’s platform, it is your responsibility to ensure that you handle personal information of Leads or any contacts you upload in compliance with applicable privacy laws and our terms. Key responsibilities for Clients include:

  • Providing Your Own Privacy Notice: You are responsible for providing your customers, prospects, and Leads with an appropriate privacy policy or notice of your own. If you are using a white-labeled version of the DealTrail platform under your own brand, you must have a Privacy Policy accessible to your end-users that complies with all relevant laws. This means you should disclose what personal information you collect, how you use it (including if you are using a platform like DealTrail to process it), and how individuals can exercise their rights. DealTrail’s Privacy Policy (this document) describes what we do with data in our role, but it does not cover what you as a Client do outside our platform or the details of your specific business practices.

  • Lawful Collection and Use: You must only upload, import, or collect personal data through the DealTrail platform if you have the legal right to do so. This includes obtaining any necessary consents or providing required notices. For example, if you are adding contacts to our platform to send marketing texts or emails, you must ensure you have the appropriate consent under laws like the Telephone Consumer Protection Act (TCPA) for SMS or CAN-SPAM (and analogous laws for email in other countries). You should honor all opt-out requests promptly and not use DealTrail to contact anyone who has withdrawn consent or objected to being contacted.

  • Use of DealTrail Lead Data: If DealTrail provides you with Leads (consumer data) as part of our service, you agree to use that data solely for your internal business purposes of offering real estate services to those Leads (or making a genuine referral to another professional, as appropriate). You may not resell, license, or otherwise redistribute the Leads’ personal information to any third party outside of a legitimate referral context. This prohibition protects consumer privacy and is part of our compliance with laws like the CCPA, which require that personal information obtained under a service provider relationship not be used for any other purpose.

  • Messaging and Communications Compliance: When using DealTrail’s tools to send SMS messages, emails, or make calls, you are responsible for the content and legality of those communications. DealTrail does not author or vet your messages. You must ensure your messages include any legally required disclosures (for example, identifying yourself and providing an opt-out method in mass marketing emails) and that you only contact individuals who have not opted out or who have provided the appropriate consent. DealTrail disclaims all responsibility for client messaging compliance. If we become aware of a Client grossly misusing the platform to send spam or unlawful communications, we reserve the right to take action (which could include warning, suspension, or termination of service), but primary responsibility lies with you as the sender.

  • Data Protection and Security: You should maintain the confidentiality of any personal data you download or export from DealTrail. For instance, if you export a list of leads from our platform, you should store it securely and only share it within your organization on a need-to-know basis. If a Lead exercises a privacy right with you (such as asking for deletion or access), you should fulfill that request in accordance with applicable law, including contacting DealTrail if you need assistance to delete or retrieve information from our platform.

By using our Services, Clients agree to these responsibilities and to comply with all applicable privacy and data protection laws. DealTrail may provide additional resources or a Data Processing Addendum to further clarify our respective obligations when handling personal information. Remember that protecting consumer privacy is a shared responsibility – we do our part as a service provider, and Clients must do theirs as the consumer-facing entity.

Changes to this Privacy Policy

We may update or revise 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 Privacy Policy. For significant changes, we may also provide a more prominent notice, such as by email to our registered Clients or a notification on our website or dashboard.

Your continued use of DealTrail’s Services after any updates to this Privacy Policy constitutes your acknowledgment of the changes and your agreement to abide by the updated policy. We encourage you to review this Policy periodically to stay informed about how we are protecting your information. If you do not agree with any changes to the Privacy Policy, you should stop using our Services and contact us with your concerns.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how your personal information is handled by DealTrail, please contact us at:

This is the designated contact for all privacy and data protection inquiries, including requests to exercise your rights. We take privacy inquiries seriously and will respond as promptly as possible.

Conclusion

By using DealTrail’s Services, you acknowledge that you have read and understood this Privacy Policy. Protecting your privacy is important to us, and we will continue to work hard to ensure that your personal information is handled safely and in compliance with all applicable laws and regulations.

© Michael Ventures LLC d/b/a DealTrail. All rights reserved.