PRIVACY POLICY

1. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies when you interact with me or David Frye Real Estate Services, including when you:

• Visit davidfryerealtor.com or another website that links to this Privacy Policy;
• Contact me about buying, selling, or relocating;
• Complete a website form;
• Request information about a home or other property;
• Request a home valuation or comparative market analysis;
• Schedule a consultation or appointment;
• Search for real estate listings;
• View or save properties;
• Save a property search;
• Create a property search account;
• Request new-listing or property alerts;
• Subscribe to market reports or real estate updates;
• Download educational real estate materials;
• Communicate with me by email, telephone, text message, website form, or another communication method;
• Engage with my real estate advertising or marketing;
• Become a prospective client, client, customer, transaction participant, or referral contact; or
• Otherwise use my Services.

My real estate services may include residential buyer representation, seller representation, relocation assistance, property marketing, property showings, comparative market analyses, home valuation services, contract negotiation, transaction coordination, consultations, market reports, community information, and educational content regarding buying, selling, and owning real estate.

This Privacy Policy does not replace disclosures, agreements, agency documents, brokerage policies, transaction documents, or other notices that may apply during an actual real estate transaction.

2. INFORMATION I MAY COLLECT

The information I collect depends on how you interact with me and the Services.

Contact and Identification Information

I may collect information such as:

• Name;
• Email address;
• Telephone or mobile telephone number;
• Contact preferences;
• Preferred communication method; and
• Other information you voluntarily include in a message or form.

Buyer and Property Search Information

If you are considering purchasing a home, I may collect information such as:

• Desired cities, communities, neighborhoods, counties, or geographic areas;
• Price range or target purchase price;
• Property type;
• Number of bedrooms or bathrooms;
• Acreage preferences;
• Garage, basement, outbuilding, or other property preferences;
• Features that are important to you;
• Properties you view, save, or inquire about;
• Saved searches;
• Property alert preferences;
• Buying timeline;
• Relocation information;
• Whether you currently own a home;
• Financing or mortgage pre-approval status; and
• Other information regarding your real estate needs.

I generally do not need detailed banking credentials, online banking passwords, or complete payment-card information through ordinary website inquiry forms. You should not submit that type of information through a general contact form, property inquiry form, or ordinary email unless a secure and appropriate process has been specifically provided.

Seller and Property Information

If you are considering selling a property, I may collect information such as:

• Property address;
• Property type;
• Home ownership status;
• General property condition;
• Improvements or renovations;
• Property features;
• Desired selling timeline;
• Selling price expectations;
• Reasons or goals related to a potential move, when voluntarily provided;
• Home valuation request information;
• Comparative market analysis information; and
• Other details reasonably needed to discuss or provide seller services.

Consultation, Appointment, and Service Information

I may collect information relating to:

• Requested consultation dates or times;
• Appointment information;
• Property showing requests;
• Real estate service requests;
• Follow-up preferences;
• Relocation needs;
• Market report requests; and
• Questions regarding buying, selling, financing, home ownership, or the real estate market.

Account and Property Search Information

When property search account features are available, information may include:

• Account or profile information;
• Email address;
• Telephone number, when requested or provided;
• Login-related account records;
• Search criteria;
• Saved searches;
• Saved or favorited properties;
• Property views;
• Property inquiries;
• Property alert selections; and
• Other activity associated with the property search tools.

Passwords and account authentication may be managed through the applicable technology provider. I may not have access to your readable password.

Communication History

I may maintain records of communications between you and me, including:

• Email communications;
• Text messages;
• Website inquiries;
• Notes concerning telephone conversations;
• Appointment and showing communications;
• Follow-up activity;
• Property inquiries; and
• Other communications related to requested or provided Services.

These records may be maintained in my email system, CRM, database, property search system, brokerage systems, or other business systems.

Real Estate Transaction Information

If you become involved in a real estate transaction, additional information may be created, received, or maintained in connection with the transaction.

Depending on the transaction, this may include:

• Agency and representation information;
• Property information;
• Offers and counteroffers;
• Purchase agreements;
• Listing agreements;
• Transaction timelines;
• Inspection-related information;
• Repair negotiations;
• Appraisal-related information;
• Closing information;
• Title or escrow communications;
• Lender or financing status information;
• Proof of funds or financial qualification information when appropriate;
• Transaction correspondence; and
• Other documents or information reasonably related to the transaction.

Some information arising in an actual transaction may be confidential or financially sensitive. That information is handled according to applicable legal, brokerage, contractual, and professional obligations.

Information You Voluntarily Provide

You are responsible for ensuring that information you provide is accurate and complete to the best of your knowledge.

Please notify me if information relevant to an ongoing service or transaction materially changes.

3. HOW INFORMATION IS COLLECTED

I may collect information directly from you when you:

• Complete a contact form;
• Request property information;
• Request a home valuation;
• Ask for a comparative market analysis;
• Create a property search account;
• Search or save properties;
• Save a search;
• Request a property alert;
• Subscribe to email communications;
• Download educational content;
• Schedule a consultation;
• Request a showing;
• Send an email;
• Call or text me;
• Meet with me;
• Enter into a buyer, seller, or other real estate relationship; or
• Otherwise voluntarily provide information.

I may also receive limited information through services or platforms that you use to contact or interact with me. For example, a property search provider may transmit your inquiry and property activity to me, or a referral source may provide your contact information when you have requested or agreed to an introduction.

During a real estate transaction, information may also be received from parties involved in or supporting the transaction, such as my brokerage, cooperating real estate professionals, title or closing providers, attorneys, lenders or mortgage professionals, inspectors, appraisers, and transaction service providers, when reasonably necessary or authorized.

I do not operate my business primarily by purchasing personal information from consumer data brokers. However, information may be received through lead, advertising, referral, real estate, or technology platforms when you have interacted with those services or requested real estate information.

4. INFORMATION COLLECTED AUTOMATICALLY

When you visit davidfryerealtor.com or use online Services, certain technical and usage information may be collected automatically by the website or service providers.

Depending on the technologies in use, this information may include:

• Internet Protocol address;
• Browser type;
• Browser settings;
• Device type;
• Device identifiers;
• Operating system;
• Internet service or network-related information;
• Referring website or page;
• Pages viewed;
• Links or website features used;
• Property search activity;
• Approximate location derived from an IP address;
• Dates and times of visits;
• Session activity;
• Error, crash, or diagnostic information; and
• Similar technical or usage information.

This information is generally used to operate, secure, analyze, troubleshoot, and improve the Services.

Automatically collected information may also be used to understand how visitors interact with the website, measure marketing effectiveness, remember preferences, prevent abuse, and support advertising where applicable.

Approximate location information derived from an IP address is different from precise GPS location. I do not intentionally request continuous precise GPS tracking through ordinary real estate website forms.

5. BUYING BUDDY IDX AND PROPERTY SEARCH SERVICES

I may use Buying Buddy to provide IDX property search features and related real estate technology.

Buying Buddy features may allow you to:

• Search available real estate listings;
• View property information;
• Save properties;
• Save search criteria;
• Create a property search account;
• Request information about a property;
• Request property alerts;
• Receive new-listing or property updates; and
• Manage aspects of your property search.

When you use these features, Buying Buddy or related property search systems may process information associated with your account, contact information, search preferences, saved properties, saved searches, property inquiries, and property search activity.

Information about your property interests and search activity may be made available to me so that I can better understand your real estate needs, respond to inquiries, provide relevant property information, and follow up regarding requested real estate services.

For example, if you save a property, request additional information, create a property alert, or repeatedly search for homes matching particular criteria, that activity may help me understand the types of properties in which you have expressed an interest.

Property search activity is not a guarantee that I will contact you regarding every property you view, and viewing a property online does not create an agency or brokerage relationship by itself.

Account registration, authentication, alerts, and other property search features may also be subject to Buying Buddy's own privacy terms, policies, or technology practices.

6. MLS AND PROPERTY LISTING INFORMATION

Property information displayed through the website may originate from one or more participating Multiple Listing Service organizations, commonly referred to as MLS organizations, and may be displayed using Internet Data Exchange, or IDX, technology.

Listing information is believed to be reliable but is not guaranteed.

Real estate listing information can change quickly. A property may:

• Receive an offer;
• Go under contract;
• Change price;
• Return to active status;
• Expire;
• Be withdrawn;
• Be sold;
• Have information corrected; or
• Otherwise change without prior notice.

Information displayed online may not always reflect a change immediately.

Property details, measurements, square footage, acreage, school information, taxes, property features, utility information, and similar listing information should be independently verified when material to a purchasing or real estate decision.

The presence of a listing on the website does not necessarily mean that I am the listing agent for that property.

MLS, IDX, and property search information is provided for real estate search and informational purposes and should not be considered an independent appraisal, inspection, survey, title opinion, legal opinion, mortgage approval, or guarantee regarding a property.

7. HOME VALUATION AND COMPARATIVE MARKET ANALYSIS REQUESTS

You may be able to request a home valuation, market analysis, or comparative market analysis through the website or by contacting me.

When you request this type of service, I may collect and use information such as:

• Your name;
• Email address;
• Telephone number;
• Property address;
• Property type;
• Known property features;
• Improvements or renovations;
• General condition information;
• Selling timeline; and
• Other property information you provide.

I may use property information, MLS information, public property information, market data, comparable properties, and my professional real estate experience to prepare or discuss a comparative market analysis.

Information submitted through a home valuation request may be used to:

• Research the property;
• Prepare or discuss a comparative market analysis;
• Provide general market information;
• Contact you regarding your request;
• Follow up regarding the property;
• Provide relevant market updates; and
• Offer seller or other real estate services.

A comparative market analysis or informal home valuation is not necessarily an appraisal and should not be represented as a licensed appraisal unless prepared by a properly licensed or certified appraiser in accordance with applicable law.

Requesting a home valuation or comparative market analysis does not obligate you to hire me, list your property with me, or enter into a brokerage relationship.

8. CRM, DATABASE, AND LEAD MANAGEMENT SYSTEMS

I use technology to organize inquiries, communications, appointments, follow-up activities, and real estate relationships.

This may include a customer relationship management system, commonly called a CRM, and database technology built with or supported by Supabase.

Information maintained in CRM or database systems may include:

• Name;
• Email address;
• Telephone number;
• Lead or inquiry source;
• Buyer or seller interests;
• Property preferences;
• Property addresses;
• Communication history;
• Follow-up notes;
• Appointment information;
• Showing information;
• Real estate timeline;
• Saved property or inquiry information;
• Contact status; and
• Other information reasonably related to providing or managing real estate services.

I may use CRM and database information to:

• Respond to inquiries;
• Remember prior conversations;
• Manage follow-up;
• Schedule or track appointments;
• Provide property information;
• Coordinate communications;
• Manage buyer and seller relationships;
• Deliver requested information;
• Reduce duplicate communications; and
• Improve the consistency and quality of my Services.

CRM and database information may be processed through workflow, email, and communication services used in my business.

9. HOW I USE PERSONAL INFORMATION

I may use personal information for the purposes described in this Privacy Policy, including to:

Provide Real Estate Services

I may use information to:

• Respond to real estate inquiries;
• Provide buyer representation;
• Provide seller representation;
• Provide relocation assistance;
• Schedule consultations;
• Schedule or coordinate property showings;
• Research properties;
• Prepare comparative market analyses;
• Discuss home valuations;
• Market listed properties;
• Communicate regarding offers or negotiations;
• Coordinate transaction activities;
• Provide market information; and
• Otherwise provide requested real estate services.

Communicate With You

I may use your contact information to:

• Respond to questions;
• Return calls or messages;
• Follow up on an inquiry;
• Provide requested property information;
• Confirm appointments;
• Send showing information;
• Discuss buying or selling needs;
• Provide transaction updates; and
• Maintain an ongoing professional relationship.

Personalize Property and Market Information

Information regarding your property interests may be used to provide more relevant:

• Property recommendations;
• Listing alerts;
• Market reports;
• Neighborhood information;
• Seller information;
• Buyer education; and
• Other real estate-related information.

Operate and Improve the Website

Technical and usage information may be used to:

• Maintain website functionality;
• Troubleshoot problems;
• Prevent misuse;
• Improve navigation;
• Understand visitor activity;
• Improve website content;
• Measure the effectiveness of website features; and
• Develop better educational and real estate resources.

Manage Accounts and Property Search Features

I or applicable service providers may use information to:

• Create or maintain property search accounts;
• Authenticate account access;
• Save property preferences;
• Maintain saved searches;
• Deliver property alerts; and
• Manage account-related requests.

Marketing and Advertising

When permitted, information may be used to:

• Send relevant real estate communications;
• Measure marketing effectiveness;
• Understand which content is useful;
• Create marketing audiences;
• Deliver or measure advertising; and
• Improve promotional campaigns.

Security and Fraud Prevention

Information may be processed to:

• Detect suspicious activity;
• Protect systems and accounts;
• Prevent fraud or misuse;
• Investigate security incidents;
• Troubleshoot technical issues; and
• Protect my rights, clients, business, service providers, or others.

Legal and Regulatory Compliance

Information may be processed or retained to:

• Comply with applicable law;
• Satisfy brokerage requirements;
• Maintain transaction records;
• Respond to lawful government requests;
• Respond to court orders or subpoenas;
• Establish or defend legal claims;
• Meet tax or accounting requirements; and
• Fulfill professional or regulatory obligations.

Other Purposes With Your Direction or Consent

I may use information for another purpose when you direct me to do so, when the purpose is reasonably apparent from the circumstances, or when legally required consent has been obtained.

10. EMAIL COMMUNICATIONS AND MARKETING

I may send real estate-related email communications when you request information, subscribe to updates, establish a property search, engage with my Services, or otherwise provide an email address in connection with real estate services.

Email communications may include:

• Responses to inquiries;
• Property information;
• Property alerts;
• New listings;
• Price changes;
• Market reports;
• Real estate market updates;
• Homeowner tips;
• Buyer education;
• Seller education;
• Community information;
• Relocation information;
• Consultation follow-up;
• Real estate newsletters; and
• Other real estate-related communications.

Some communications are service-related rather than marketing communications. For example, I may need to send an email regarding a property you specifically asked about, an appointment, an active property search, or an ongoing transaction.

Marketing or promotional emails may include an unsubscribe link when required or appropriate.

You may unsubscribe from marketing email communications by using the unsubscribe link in the email or by contacting me at david@davidfryerealtor.com.

After an unsubscribe request is processed, I may still communicate with you for non-marketing purposes, including to:

• Respond to a direct inquiry;
• Provide information you requested;
• Administer a property search account;
• Communicate regarding an appointment;
• Communicate regarding a client relationship; or
• Complete or manage an active real estate transaction.

Unsubscribing from general marketing does not necessarily cancel a property alert or other service you have separately requested. Property alerts may need to be managed through the applicable property search account or by contacting me.

11. SMS AND TEXT MESSAGE COMMUNICATIONS

When you provide a mobile telephone number and consent to or otherwise request text communication, I may use text messages for real estate-related communications.

Depending on your interaction with me, text messages may include:

• Responses to your inquiries;
• Property information;
• Showing information;
• Appointment confirmations or reminders;
• Follow-up communications;
• Property search updates;
• Buyer or seller communications;
• Market-related information; and
• Other real estate-related messages.

Message frequency may vary depending on your requests, property search activity, communication preferences, and whether you are involved in an active real estate transaction.

Message and data rates may apply depending on your mobile carrier and service plan.

You may opt out of marketing or automated text communications by replying STOP or by using another reasonable opt-out method communicated to me. You may also contact me at david@davidfryerealtor.com regarding your communication preferences.

Where supported by the messaging system, you may reply HELP for assistance.

Consent to receive marketing text messages is not a condition of purchasing a property, selling a property, or receiving real estate brokerage services unless a specific communication is reasonably necessary to provide a service you separately requested.

Opting out of marketing or automated texts does not prevent you from contacting me directly. It also does not necessarily prevent individual, non-marketing communications that you specifically request or communications reasonably necessary regarding an ongoing transaction, to the extent permitted by applicable law and your communication preferences.

Mobile telephone information, text-message opt-in information, and text-message consent records will not be shared with third parties or affiliates for their own marketing or promotional purposes.

Service providers supporting text delivery, customer support, communications, CRM functions, or related business operations may process this information only as reasonably necessary to provide those supporting services. Text-message originator opt-in data and consent are not provided to third parties for unrelated marketing purposes.

12. COOKIES, PIXELS, AND SIMILAR TECHNOLOGIES

The website and service providers may use cookies and similar tracking technologies, including web beacons, pixels, tags, local storage, and related technologies.

A cookie is a small data file that may be stored on your device when you visit a website.

Cookies and similar technologies may be used to:

• Enable website functionality;
• Maintain website security;
• Prevent abuse;
• Save visitor preferences;
• Remember certain selections;
• Support property search functions;
• Maintain account or session functionality;
• Troubleshoot errors;
• Analyze website traffic;
• Understand how visitors use the website;
• Measure marketing performance;
• Measure advertising effectiveness; and
• Support personalized or interest-based advertising where enabled.

Some cookies may be necessary for the website to function properly. Other cookies may support analytics, advertising, or optional website features.

Where required by applicable law, consent choices may be provided through a cookie banner or cookie preference tool.

You may also be able to manage cookies through your browser settings. Blocking or deleting cookies may affect the functionality of portions of the website, property search tools, account functions, or visitor preferences.

13. ANALYTICS AND DIGITAL ADVERTISING

I may use analytics and advertising technologies to understand website usage and improve marketing.

Google Analytics and Google Technologies

I may use Google Analytics or related Google technologies to analyze the use of the website.

Depending on configuration and consent choices, Google Analytics or related technologies may process information such as:

• Website activity;
• Browser information;
• Device information;
• Approximate geographic information;
• Referral information; and
• Other online identifiers or usage information.

This information may help me understand:

• Which website pages are visited;
• How visitors navigate the website;
• Which content is useful;
• General website traffic patterns; and
• The effectiveness of marketing activities.

I may also use Google Maps or other Google mapping services to provide maps, location information, or geographically relevant website features.

Google services may process information according to Google's own privacy terms and settings.

Meta and Facebook Technologies

If enabled, I may use Meta or Facebook advertising and tracking technologies, including the Meta Pixel or similar services.

These technologies may be used to:

• Measure advertising performance;
• Understand whether website visitors interacted with an advertisement;
• Create advertising audiences;
• Improve advertising relevance;
• Measure conversions; and
• Deliver or support interest-based advertising.

Meta and other advertising providers may use cookies, pixels, or similar technologies in accordance with their own policies.

Your browser, cookie preference tools, advertising platform settings, and rights under applicable state law may provide choices regarding some advertising or tracking activities.

Advertising Is Not the Same as Selling a Lead List

The use of online advertising technologies may involve the transmission of online identifiers or website activity to advertising providers.

This is different from operating a business that sells consumer names, telephone numbers, or real estate lead lists for cash.

However, certain U.S. state privacy laws may define terms such as "sale," "sharing," "targeted advertising," or "cross-context behavioral advertising" more broadly. Section 20 explains this distinction in greater detail.

14. ARTIFICIAL INTELLIGENCE AND AI-ASSISTED TOOLS

I may use artificial intelligence, machine learning, or AI-assisted tools to support aspects of my real estate business.

AI-assisted tools may be used for purposes such as:

• Administrative assistance;
• Drafting communications;
• Organizing or summarizing information;
• Marketing content;
• Property description drafts;
• Educational real estate content;
• Website content;
• Research assistance;
• Text analysis;
• Workflow support;
• Internal business efficiency; and
• Other administrative or communication tasks.

AI is used as an assistance tool. It does not replace my professional judgment as a licensed real estate agent.

I do not use AI as the sole automated decision-maker to determine whether a person is eligible to receive real estate brokerage services.

When AI-assisted tools are used, I seek to limit personal information submitted to those tools to information reasonably necessary for the task. However, information processed through an AI tool may be processed by a third-party AI technology provider.

The privacy and security practices of an AI provider may be governed by the provider's own contractual terms and privacy practices.

You should not submit passwords, bank login information, Social Security numbers, or other highly sensitive credentials through an AI chatbot, general website form, or ordinary real estate inquiry unless a secure process specifically requires the information.

AI-generated drafts, summaries, or content may contain errors and are subject to human review when used in connection with material real estate services.

15. HOW AND WHEN PERSONAL INFORMATION MAY BE SHARED

I may disclose or make personal information available when reasonably necessary for the purposes described in this Privacy Policy.

Information may be shared with the following categories of recipients:

• Website and technology providers;
• IDX and property search providers;
• CRM and database providers;
• Email delivery providers;
• Workflow automation providers;
• Cloud or communication providers;
• Analytics providers;
• Advertising providers;
• River Valley Realty;
• Cooperating real estate brokers or agents;
• Title companies;
• Closing or escrow providers;
• Attorneys;
• Lenders or mortgage professionals when authorized or appropriate;
• Inspectors;
• Appraisers;
• Contractors or other property professionals;
• Transaction management or service providers;
• Other licensed real estate professionals involved in a referral;
• Accountants or professional advisors;
• Government or regulatory authorities; and
• Other parties when you request, authorize, or direct the disclosure.

I do not provide every category of information to every recipient.

The information disclosed depends on the service being provided and the reason for the disclosure.

For example, an email delivery provider may need an email address to deliver an email. A property search provider may process search criteria and saved properties. A title company may receive information reasonably related to a transaction.

I seek to limit disclosures to information reasonably related to the applicable purpose.

16. TECHNOLOGY AND SERVICE PROVIDERS

I use or may use third-party service providers to operate my business and provide the Services.

Depending on the technologies and features in use, providers may include:

• Squarespace for website hosting, website features, and related website technology;
• Buying Buddy for IDX property search, saved searches, property alerts, property search accounts, and related real estate technology;
• Supabase for database, CRM, authentication, application, or backend technology;
• Resend for email delivery or related email infrastructure;
• Zapier for workflow automation and integrations;
• Google Workspace for email, documents, communications, or other business productivity services;
• Google Analytics for website analytics;
• Google Maps or other Google mapping services for map or location-related functionality; and
• Meta or Facebook advertising and tracking services, if enabled, for advertising, audience measurement, and marketing analytics.

I may also use additional service providers for scheduling, document management, transaction management, electronic signatures, website functions, communications, cybersecurity, accounting, or other legitimate business operations.

Technology providers may process information as reasonably necessary to provide services on my behalf or to support the functionality through which you interact with them.

Third-party providers maintain their own systems, terms, security practices, and privacy policies.

The specific providers I use may change as my business and technology needs develop. This Privacy Policy may be updated when a change materially affects the privacy practices described here.

17. RIVER VALLEY REALTY AND MY BROKERAGE RELATIONSHIP

David Frye is a licensed Ohio real estate agent affiliated with River Valley Realty.

As an affiliated real estate licensee, I provide licensed real estate services through my brokerage relationship.

Personal or transaction information may be shared with or made available to River Valley Realty when reasonably necessary to:

• Provide brokerage services;
• Establish or manage an agency or client relationship;
• Supervise licensed real estate activity;
• Manage transactions;
• Review transaction documentation;
• Maintain brokerage records;
• Administer brokerage systems;
• Address compliance or risk-management matters;
• Respond to client or consumer concerns;
• Satisfy legal or regulatory obligations; and
• Perform other legitimate brokerage functions.

Information provided to River Valley Realty may be subject to brokerage policies, technology systems, document retention practices, and legal obligations that are separate from my independent website operations.

This Privacy Policy does not modify any agency disclosure, brokerage agreement, buyer representation agreement, listing agreement, or other real estate agreement.

18. REAL ESTATE TRANSACTIONS AND TRANSACTION PROFESSIONALS

Real estate transactions often require communication and coordination among multiple parties.

If you become involved in a transaction, information may need to be shared with appropriate parties to negotiate, manage, or complete that transaction.

Depending on the circumstances, these parties may include:

• Sellers;
• Buyers;
• Cooperating real estate brokers;
• Cooperating real estate agents;
• River Valley Realty;
• Title companies;
• Closing or escrow providers;
• Attorneys;
• Lenders;
• Mortgage professionals;
• Inspectors;
• Appraisers;
• Surveyors;
• Contractors;
• Home warranty providers;
• Insurance professionals when directed or appropriate;
• Transaction coordinators;
• Electronic signature or document providers;
• Government offices; and
• Regulatory authorities.

Information is shared based on the transaction, your instructions, contractual responsibilities, professional duties, legal requirements, and what is reasonably necessary to provide the applicable service.

I do not control the independent privacy practices of every professional or company participating in a real estate transaction.

You may wish to review the privacy practices of lenders, title companies, inspectors, attorneys, and other independent service providers before providing them with sensitive personal or financial information.

19. REAL ESTATE REFERRALS

My primary service area is in Northeast Ohio.

If you request help buying or selling real estate outside my normal service area, I may offer to connect you with another licensed real estate professional.

With your permission, I may provide the referred real estate professional with limited information such as:

• Your name;
• Contact information;
• General location needs;
• Whether you are buying or selling;
• General price range;
• Real estate timeline; and
• Other information reasonably necessary to facilitate the introduction.

I will not intentionally provide substantially more information than is reasonably necessary for the referral without an appropriate reason, direction, or authorization.

A referral relationship may involve a referral agreement or referral compensation between licensed real estate professionals or brokerages where permitted by applicable real estate law.

The receiving real estate professional and brokerage are responsible for their own privacy and data-handling practices.

20. SALE, SHARING, AND TARGETED ADVERTISING DISCLOSURES

I do not operate a consumer data brokerage and do not regularly sell consumer names, mobile telephone numbers, email addresses, or real estate lead lists to unrelated companies for cash as a core business activity.

However, privacy laws in some U.S. states define "sale" or "sharing" of personal information more broadly than an ordinary cash sale.

For example, depending on applicable law and the configuration of website technologies, the use of certain advertising cookies, pixels, or online identifiers may be considered:

• A sale of personal information;
• Sharing of personal information;
• Targeted advertising; or
• Cross-context behavioral advertising.

This may be the case even when no money is paid for the specific personal information.

If an applicable privacy law gives you the right to opt out of a covered sale, sharing activity, or targeted advertising, I will honor valid requests as required by that law when the law applies to my business and the relevant processing activity.

You may contact me at david@davidfryerealtor.com regarding a privacy or advertising request.

Cookie preference tools, browser settings, Global Privacy Control signals when legally required to be recognized, and advertising platform settings may also provide privacy choices depending on the technology involved.

Nothing in this section authorizes the sharing of text-message opt-in data or consent information with third parties for their own marketing or promotional purposes.

21. LEGAL COMPLIANCE AND OHIO REAL ESTATE OBLIGATIONS

I may process, retain, or disclose information when reasonably necessary to comply with applicable law or professional obligations.

This may include purposes related to:

• Ohio real estate licensing requirements;
• Brokerage supervision and compliance;
• Real estate transaction recordkeeping;
• Agency obligations;
• Legal claims;
• Court orders;
• Subpoenas;
• Government requests;
• Regulatory investigations;
• Fraud prevention;
• Security investigations;
• Tax requirements;
• Accounting obligations;
• Insurance or risk-management matters; and
• Enforcing applicable agreements or protecting legal rights.

I may also preserve information when I reasonably believe it is necessary to prevent the destruction of evidence, respond to a dispute, investigate suspected wrongdoing, or comply with a legal preservation requirement.

A deletion request does not necessarily require deletion of records that must be retained for legal, regulatory, contractual, fraud-prevention, security, or legitimate recordkeeping purposes.

22. BUSINESS TRANSFERS

If all or part of David Frye Real Estate Services is involved in a business reorganization, merger, acquisition, financing, asset sale, transition, or similar business event, information may be disclosed or transferred as part of evaluating, negotiating, or completing that event.

Any recipient of personal information in a business transfer would be expected to handle the information subject to applicable law and any commitments that continue to apply.

This section does not mean that a business transfer is planned. It describes how information may be handled if such an event occurs.

23. SENSITIVE AND CONFIDENTIAL INFORMATION

I do not intentionally request information concerning racial or ethnic origin, religious beliefs, sexual orientation, or similar highly sensitive personal characteristics through ordinary website inquiry, property search, or home valuation forms.

You should not provide this type of information through a general website form unless there is a legitimate and appropriate reason to do so.

Real estate transactions can, however, create or involve confidential or financially related information.

For example, transaction information may include:

• Financing status;
• Pre-approval status;
• Proof of funds information;
• Negotiation information;
• Transaction documents; or
• Other confidential information relevant to buying or selling real estate.

When confidential or financially related information is reasonably necessary, it may be processed, stored, or shared with appropriate parties as described in this Privacy Policy and as required by applicable brokerage, contractual, professional, or legal obligations.

I do not use confidential transaction or financial qualification information for unrelated behavioral advertising merely because that information was received during a transaction.

Please use care when sending sensitive documents by ordinary email or text message. Where an appropriate secure document or transaction system is available, you may be directed to use that system.

24. HOW LONG INFORMATION IS RETAINED

I retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, unless a longer period is required or permitted by law.

Retention periods may depend on:

• The nature of the information;
• Whether you have an active property search account;
• Whether you requested ongoing property alerts;
• Whether you remain a prospective buyer or seller;
• Whether I am continuing to provide Services;
• Whether you became a client;
• Whether a real estate transaction occurred;
• Brokerage requirements;
• Ohio real estate recordkeeping obligations;
• Tax or accounting obligations;
• Security or fraud-prevention needs;
• Dispute resolution;
• Legal claims; and
• Other applicable legal requirements.

For example, transaction records may need to be maintained for a legally or professionally required retention period even after a transaction closes or a client relationship ends.

When information is no longer reasonably necessary and no applicable reason requires continued retention, it may be deleted, anonymized, or securely disposed of where reasonably practicable.

Information stored in backups may remain for a limited period until ordinary backup deletion or rotation processes occur.

When a property search or other account is terminated, account information may be deleted or deactivated from active systems. Some information may nevertheless be retained to prevent fraud, troubleshoot problems, respond to investigations, maintain business records, enforce agreements, or comply with legal requirements.

25. HOW PERSONAL INFORMATION IS PROTECTED

I use reasonable administrative, organizational, and technical measures designed to protect personal information.

Depending on the systems involved, safeguards may include:

• Account authentication;
• Access controls;
• Secure service providers;
• Software and system updates;
• Data access limitations;
• Password protections;
• Encrypted communications or storage where supported;
• Security monitoring;
• Backup practices; and
• Other reasonable security measures.

Despite these efforts, no internet transmission, email system, text messaging system, website, database, cloud platform, or electronic storage technology can be guaranteed to be completely secure.

I cannot promise or guarantee that unauthorized persons, hackers, cybercriminals, or other third parties will never defeat security measures or improperly collect, access, steal, disclose, or modify information.

You are responsible for using reasonable care when communicating online and protecting account credentials.

You should:

• Use strong and unique passwords;
• Avoid sharing account credentials;
• Use secure devices and networks;
• Be cautious of unexpected requests for money or financial information; and
• Contact me through a known communication method if you receive a suspicious real estate-related message.

Real estate wire fraud and impersonation attempts can involve fraudulent emails or messages. Always independently verify wiring or financial instructions directly with the appropriate title, closing, lender, or other responsible professional using a trusted communication method.

Transmission of information to and from online Services is undertaken with the understanding that electronic communications involve inherent risks.

26. CHILDREN'S PRIVACY AND MINORS

The Services are intended primarily for adults seeking real estate information or real estate services.

I do not knowingly collect personal information directly from or market real estate services to children under 18 years of age through the website.

By independently creating an account or submitting personal information for your own use, you represent that you are at least 18 years old or are otherwise legally authorized to provide the information.

A parent or legal guardian may use the Services in connection with a household or family real estate decision.

If I learn that personal information has been collected directly from a person under 18 without appropriate authorization, I may deactivate an applicable account and take reasonable steps to delete the information, subject to legal or recordkeeping requirements.

If you believe I may have received personal information directly from a child under 18 inappropriately, please contact me at david@davidfryerealtor.com.

27. U.S. STATE PRIVACY RIGHTS

Residents of certain U.S. states may have privacy rights under applicable state law.

Whether a particular state privacy law applies depends on factors that may include:

• Your state of residence;
• The type of information involved;
• The nature of the processing;
• The size or activities of the business; and
• Statutory exemptions or applicability thresholds.

This Privacy Policy does not state that every U.S. state privacy law applies to David Frye Real Estate Services.

When an applicable privacy law applies, you may have one or more of the following rights:

• The right to confirm whether personal information is being processed;
• The right to access personal information;
• The right to obtain certain information about processing activities;
• The right to correct inaccuracies;
• The right to request deletion;
• The right to obtain a portable copy of certain personal information;
• The right to opt out of a covered sale of personal information;
• The right to opt out of certain sharing activities;
• The right to opt out of targeted advertising;
• The right to limit or control certain uses of sensitive personal information;
• The right to withdraw consent where consent is the basis for processing;
• The right to use an authorized agent where permitted;
• The right to appeal certain privacy request decisions; and
• The right not to receive unlawful discriminatory treatment for exercising a privacy right.

These rights are subject to applicable exceptions and limitations.

For example, I may be permitted or required to retain information necessary to:

• Complete a transaction;
• Provide a requested service;
• Comply with legal requirements;
• Maintain real estate or brokerage records;
• Protect against fraud;
• Investigate security incidents;
• Exercise or defend legal claims; or
• Perform other activities permitted by applicable law.

California and residents of other states with privacy laws may have additional rights or disclosure rights when the applicable statute covers my business and processing activities.

I will evaluate privacy requests based on the law that applies at the time the request is received.

28. ACCESS, CORRECTION, DELETION, AND PRIVACY REQUESTS

You may contact me to request access to, correction of, or deletion of personal information.

Privacy requests should be sent to:

David Frye
Email: david@davidfryerealtor.com

Please clearly describe the nature of your request.

Depending on the request and applicable law, I may need to verify your identity before providing information or taking action.

Identity verification may involve asking you to confirm information reasonably related to your prior interactions with me.

I will not request more identity verification information than reasonably necessary for the request and applicable security concerns.

If I cannot reasonably verify your identity, I may be unable to fulfill some requests.

Authorized Agents

Where applicable law permits an authorized agent to submit a request on your behalf, I may request information reasonably necessary to:

• Verify your identity;
• Confirm the agent's authority; and
• Protect against fraudulent requests.

An authorized agent may be required to provide written permission or other legally sufficient evidence of authority.

Responding to Requests

I will consider and respond to valid privacy requests in accordance with applicable law.

A request may be denied or limited when an exception applies.

If I deny or limit a request and applicable law requires an explanation, I will provide the required information.

Appeals

If applicable state law provides a right to appeal a privacy request decision, you may submit an appeal by emailing david@davidfryerealtor.com and clearly stating that you are appealing a privacy request decision.

I will review the appeal and provide a response as required by applicable law.

Where applicable law provides a further complaint process, you may also have the right to contact the appropriate state attorney general or other regulatory authority.

Property Search Accounts

If account settings allow you to review or update information directly, you may be able to make certain changes through your property search account.

You may also contact me regarding account termination or changes.

Terminating an account does not necessarily require the deletion of information that must or may lawfully be retained for transaction, legal, security, fraud-prevention, or other legitimate purposes.

29. WITHDRAWAL OF CONSENT AND COMMUNICATION PREFERENCES

Where personal information is processed based on your consent and applicable law permits withdrawal, you may withdraw that consent.

Withdrawal of consent will not generally affect the lawfulness of processing that occurred before the withdrawal.

Withdrawal also may not prevent processing that is permitted or required on another legal basis.

Email Preferences

You may unsubscribe from marketing emails by:

• Using the unsubscribe link in an applicable email; or
• Contacting me at david@davidfryerealtor.com.

You may continue to receive non-marketing communications regarding requested Services, accounts, appointments, transactions, or direct inquiries.

Text Message Preferences

You may opt out of marketing or automated texts by replying STOP or communicating another reasonable opt-out request.

I may send an appropriate confirmation of the opt-out.

Individual non-marketing communication you specifically request may be treated separately where permitted by applicable law.

Property Alerts

Property search or new-listing alerts may be managed through your property search account when those controls are available.

You may also contact me regarding property alert preferences.

General Communication Preferences

You may contact me to discuss your communication preferences.

I will make reasonable efforts to honor those preferences, subject to communications that may be necessary for an active transaction, legal requirement, requested service, or other legitimate non-marketing purpose.

30. DO NOT TRACK AND BROWSER PRIVACY CONTROLS

Some web browsers, mobile operating systems, and applications offer a Do Not Track, or DNT, setting intended to communicate a preference regarding online tracking.

There is not a single universally implemented technical standard governing how all websites and online services must interpret traditional DNT signals.

As a result, the website may not respond to traditional DNT browser signals unless applicable law requires otherwise or the website's technology is configured to do so.

If a legally binding or widely adopted standard changes the obligations applicable to the Services, this Privacy Policy may be updated to describe the applicable practice.

Other browser or device privacy controls may affect cookies and online tracking.

Depending on applicable law and the technologies in use, privacy preference signals such as Global Privacy Control may be recognized when legally required.

You may also use:

• Browser cookie controls;
• Cookie preference tools;
• Advertising platform privacy settings;
• Device privacy settings; and
• Other available privacy technologies.

Blocking tracking technologies may affect certain website or property search features.

31. INTERNATIONAL PROCESSING AND DATA TRANSFERS

David Frye Real Estate Services is based in the United States and primarily provides real estate services in Ohio.

The website and technology providers used to operate the Services may maintain servers, personnel, subprocessors, or technology infrastructure in different states or countries.

As a result, information may be processed or stored outside Ohio and, in some circumstances, outside the United States.

Privacy laws in another jurisdiction may differ from the laws where you reside.

When applicable law requires safeguards for a cross-border data transfer, I or the relevant service provider may rely on legally recognized transfer mechanisms, contractual protections, or other lawful safeguards.

My use of a third-party technology provider does not necessarily mean that every category of personal information is transferred internationally.

The location and processing practices of a service provider are generally governed by that provider's infrastructure, contractual commitments, and applicable law.

32. THIRD-PARTY WEBSITES AND SERVICES

The website may contain links to independent third-party websites or services.

Examples may include:

• Lenders;
• Title companies;
• Inspectors;
• Government websites;
• Community resources;
• Social media platforms;
• Mapping services;
• Real estate resources; and
• Other third-party businesses.

A link does not necessarily mean that I own, operate, control, or endorse the privacy practices of the third party.

Once you leave my website or interact directly with an independent service, the third party may collect information under its own privacy policy.

I am not responsible for the privacy, security, content, or data practices of independent third-party websites or services that I do not control.

You should review the privacy policies of third parties before providing them with personal or sensitive information.

33. CHANGES TO THIS PRIVACY POLICY

I may update this Privacy Policy from time to time.

Changes may be made to reflect:

• New website features;
• Changes in property search technology;
• New service providers;
• Changes in marketing practices;
• Changes in data practices;
• Legal or regulatory developments;
• Security improvements; or
• Changes in my real estate business.

When this Privacy Policy is updated, the "Last Updated" date at the top of the policy will be revised.

Material changes may also be communicated through the website or another reasonable method when appropriate or required by law.

You are encouraged to review this Privacy Policy periodically.