Privacy Policy for Auctm

Squadrun Inc. (“Squadrun,” “we,” “us,” or “our”), including our affiliates, respect your privacy and understand that you care about your Personal Information (defined below) and how it is used. This privacy policy (“Privacy Policy”) describes in detail the types of information we collect about you, how we use your information and with whom we share it.
1. Scope:
This Privacy Policy applies to the use of the Services (as defined below) by Agents, Team Leads and Brokers. “Agent(s)” refers to individuals who are licensed with the applicable real estate authority to act as real estate agents and engage in the business of buying and selling real estate on behalf of their clients. “Broker(s)” refers to companies, other organizations or persons who are licensed with the applicable real estate authority to act as real estate brokers and negotiate and oversee real estate transactions. “Team Lead(s)” refers to team leads overseeing the conduct of individual employees of Brokers. Except as otherwise indicated, Agents, Brokers, Team Leads and other persons using the Services are individually and collectively referred to as “you” or “user”.
This Privacy Policy applies to Personal Information collected by Squadrun through its integrated application (“Auctm”) provided through its Website (as defined in the Terms of Use) and mobile application. Auctm is an artificial intelligence driven, real estate assistance application for Agents, Team Leads and Brokers (as defined in the Privacy Policy) which focuses on empowering them to make data driven decisions by improving data visibility and understanding in the field of real estate sales. It displays dashboards for each Agent, Team Lead and Broker availing the Services (defined below), which contain periodic actionable insights and details regarding areas of improvement for the Agent/ Broker’s business. It also helps Agents, Team Leads and Brokers manage and track Leads (defined below), prepare and share notes on Lead generation and management, to facilitate high levels of productivity for Agents, Team Leads and Brokers. The services we provide you through Auctm shall be referred to as “Services”.
2. Definitions:
2.1. ”Agent(s)” shall have the meaning attributed to it in Clause 1 of this Privacy Policy.2.2. “Auctm Account” shall have the meaning attributed to it in Clause 3.1.2 of this Privacy Policy. 2.3. “Broker(s)” shall have the meaning attributed to it in Clause 1 of this Privacy Policy.2.4. “Business Purpose” shall have the meaning attributed to it under the CCPA. 2.5. “CCPA means the California Consumer Privacy Act, 2018.2.6. “Consumer” shall have the meaning attributed to it in Clause 11 of this Privacy Policy.2.7. “Data” means the Personal Information that we obtain when we (a) collect your Personal Information from you when you access the Services; (b) collect your Personal Information through cookies and data analytics; and (c) collect from publicly accessible databases for the purpose of providing our Services.2.8. “Lead(s)” shall have the meaning attributed to it in Clause 3.1.3 of this Privacy Policy.2.9. “Online Payment Gateway Service Provider” or “OPGSP” shall have the meaning attributed to it in Clause 6 of this Privacy Policy.2.10. “Personal Information” means information that identifies or relates to or is reasonably capable of being associated with, whether directly or indirectly, with a particular consumer or household.2.11. “SAAS” means the software underlying Auctm.2.12. “Services” shall have the meaning attributed to it in Clause 1 of this Privacy Policy.2.13. “Team Lead(s)” shall have the meaning attributed to it in Clause 1 of this Privacy Policy. 
3. Information we collect and obtain
We obtain Personal information and non-personally identifiable information about you from a variety of sources. This includes information you provide to us directly, information we obtain from other sources, and information we gather through automated means.
Information you provide to us3.1.1. Information collected from AgentsWhen you register for or participate in the Services or directly correspond with us, we may collect certain types of information from you, including but not limited to:your name;your license number; andyour email address.
3.1.2. Information collected from BrokersWhen you register for or participate in the Services or directly correspond with us, we may collect certain types of information from you, including but not limited to:your name;your license number;your official email address;your office address;name of your brokerage firm or team;details of your Team Leads;details of your API key to access real estate related customer relationship management portals such as - Follow up Boss and Firepoint; List of all Agents working with you, who will access the Services through your Auctm account (“Auctm Account”); Your personal contact information, including name, residential address, email address and phone numbers;username and password for your Auctm Account when you register through our Services;your social security number or payment information, when required to facilitate certain transactions for the purpose of availing the Services; andother information you may provide to us, such as through our “Contact Us” feature.

3.1.3. Lead Information collected from Agents and BrokersWhen you avail the Services, we may collect certain types of information from you relating to leads for potential real estate transactions (“Leads”) for the purpose of providing the Services, subject to Clauses 4 and 5 below, including but not limited to:Lead’s Personal Information such as name, email address, phone number, name of spouse, name of offsprings;Leads’ budget;Time frame within which the Lead needs to purchase the property;Details regarding the properties viewed by the Lead, the number of times it was viewed and address of the property viewed;Details regarding the pre-approval process to be undergone by the Lead and the Leads’ location of interest;Details regarding the mortgage amount;Details regarding the Lead’s requirements regarding the property, such as number of rooms, number of baths etc.

Information Collected through cookies and data analytics

Auctm use cookies, which are files that are placed on your system when you use our Services, to store certain information relating to your online activities, that does not constitute your Data. The information collected through these cookies is used by us for the technical administration of our research and development, and to improve the quality of our Services.We may use third party cookies to track visitor behaviour and to improve the quality of the SAAS. However, such cookies will not store any kind of Data, nor will such information be disclosed to any third party.These cookies are intended to be automatically cleared or deleted when you stop using the SAAS. Users have a variety of third-party tools to control cookies, web beacons and similar technologies, including browser controls to block and delete cookies and controls from some third-party analytics service providers to opt out of data collection through web beacons and similar technologies. However, such controls may impact your experience with our Services.The information we collect with cookies is not sold, rented, or shared with any third parties, and is not used by us for purposes other than internal development and maintenance of the SAAS.
Notwithstanding anything mentioned in this Clause 3.2, Squadrun will routinely analyze your Data to help improve the way we run our business and the SAAS. We use your Data for data analytics, particularly to understand how our Services are used and to enhance your experience while availing our Services.

4. How we use the information we collect or obtain
We may use the information collected as per Clause 3 of this Privacy Policy to:provide our Services and create and manage Auctm Accounts ;send you notifications and communicate with you;to send you marketing communications in relation to our Services;respond to inquiries from you and other third-parties, including inquiries from law enforcement agencies in accordance with applicable law;provide you with customer support including technical support and troubleshooting;associate your browser and/or device with other browsers or devices you use for the purpose of providing relevant and easier access to the Services;operate, evaluate and improve our business (including developing, enhancing, analyzing and improving our Services; performing data and statistical analytics; and performing accounting, auditing and other internal functions);facilitate delivery of relevant advertisements and information to you on or by way of the Services or on or by way of other websites or media, including, for example, popular social media sites and features;protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities;comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our internal policies; improve the safety and reliability of the SAAS. This includes detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could harm the SAAS, you, our other users, or the general public; improve the performance of the SAAS, and to improve recommendations provided to users through the Auctm dashboard; andIn other ways for which we provide specific notice at the time of collection.

5. Who will we share your Data with?
We may share your Data with:our subsidiaries for the effective provision of Services in a manner consistent with this Privacy Policy; third parties who perform services on our behalf;our third-party clients or business partners, such as realtors, landlords, and other similar professionals to facilitate your transactions, and other third parties to serve targeted advertisements;third-party marketers, who may combine your Personal Information with their own records and records available from other sources;law enforcement authorities or other government officials if we are required to do so to comply with subpoenas, court orders, legal process or other law enforcement or other government measures, and to comply with other legal obligations. We may also disclose information if we believe disclosure is necessary or appropriate, in accordance with applicable law, in connection with an investigation of suspected or actual fraudulent or illegal activity;the relevant authority to protect and defend the rights, interests and safety of the Services, our subsidiaries, and their employees, contractors and agents; to protect the security and safety of our users of the Services, including when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss;the transferee of our business in the event of a proposed or completed sale or transfer of all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation);when the information collected from or about you is not defined as Personal Information under applicable law, we may share such non-personal, de-identified information or aggregated information with third parties at our discretion.5.2.1   We understand that sharing information with third parties is a big             responsibility. We’re committed to sharing information only when needed           for a legitimate business or legal purpose, and then only with recipients              who will protect it

6. What do we do with your billing information?
While making any payment for availing our Services, we may collect your billing details such as name, billing address, contact number and redirect you to our Online Payment Gateway Service Provider (“OPGSP”). We do not collect or store your credit/debit card details or your net-banking details on our servers. You agree and acknowledge that your submission of credit/debit card details or net-banking details to the OPGSP will be governed by the terms stipulated in the OPGSP’s terms of use and privacy policy.  

7. Your choices and rights
Your choices7.1.1. By creating an account on Auctm , you are choosing to surrender your Data to us for the purpose of availing the Services. You will not be able to access our Services without creating an Account and providing Data.7.1.2. To ask us to remove your information from our marketing mailing lists, please contact us at [●insert contact mail id]. You can also unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails. Even if you unsubscribe from our marketing communications, we may still need to send you communications relating to your use of the Services.7.1.3. You have various options to disable cookies, web beacons etc. from accessing your system, as discussed in Clause 3.2.2 above.7.1.4. We may use third-party analytics services on our Services, such as Google Analytics. The analytics providers that administer these services use technologies such as cookies, web beacons and similar technologies to help us analyze your use of the Services. To learn more about how to opt out of Google Analytics and similar services, please visit this link.7.1.5. You may also choose to opt out of use of data that we collect about your online activities to provide you with tailored advertising about products and services of interest to you. To opt out of this please contact us at [●insert contact mail id]. 

8. Accessing, correcting and deleting your Data
You may review and update the Data on your Auctm Account by logging in and editing such information on your respective dashboard. If you decide to delete all of your information, you will make it impossible for us to provide the Services to you, and we may delete your Auctm Account. 

9. Links to third-party sites, apps or services
For your convenience and information, our Services may provide links to third-party sites, apps and services that may be operated by companies not affiliated with Squadrun. These companies may have their own privacy policies, which we strongly suggest you review. We are not responsible for the privacy practices of any non-Squadrun sites, apps or services.

10. Changes to our Privacy Policy
From time to time, we may change our Privacy Policy to reflect changes to our privacy practices and Services. If we modify this Privacy Policy, we will update the “Last Modified Date” and the changes will be effective as of the date we post the amended version of the Privacy Policy. For material changes, we will notify you by posting a prominent notice on our Services indicating at the top of the Privacy Policy when it was most recently updated or by other appropriate means, such as email through the email address you most recently provided to us.
How to contact us
If you have any questions or comments about this Privacy Policy or the manner in which we treat your Data, would like to exercise your choices, or would like us to update information we have about you or your preferences, please contact us as follows:[●insert contact details]

11. Rights available to residents of California
The CCPA provides certain rights to residents of California. This Clause of the Privacy Policy applies only if you are a natural person who is a resident of California (“Consumer”) and use our Services. This Privacy Policy supplements the information in the above Clauses of this Privacy Policy. Certain terms used below have the meanings given to them in the CCPA.
11. 1. Categories of Personal Information we collect about youThe categories of Personal Information we may collect from you are:Identifiers (such as your contact information such as name and email address), government identifiers (social security numbers and professional licensing numbers) or unique personal identifiers (device ID, cookies, IP address);Commercial information (such as transaction data or purchase history);Financial information (such as credit card information) for billing purposes;Internet or other network or device activity (such as browsing history or app usage);Professional or employment related information;Education related information; andOther information that identifies or can be reasonably associated with you.
11.2. Categories of sources from which we collect Personal InformationThe sources from which we may have collected Personal Information about you or your use of the Services are:Directly from you;Through your use of the Services; andPublicly available records.
11.3. Business or commercial purposes for which we collect your Personal Information11.3.1. The business or commercial purposes (as defined under the CCPA) for which we collect the Personal Information are:providing the Services, including maintaining or servicing Auctm Accounts, verifying customer information, processing payments, providing targeted advertisements through third-parties, providing analytics services through third parties, or providing similar services;auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;debugging to identify and repair errors that impair existing intended functionality;undertaking internal research for technological development and demonstration; andundertaking activities to verify or maintain the quality or safety of the Services.
11.3.2. We may disclose your Personal Information identified in Clause 11.1 above for Business Purposes where the use of such personal information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or processed.
11.4. Categories of third parties with whom we share the Personal InformationThe categories of third parties (as defined by the CCPA) with whom we share Personal Information include our subsidiaries and affiliates; data analytics service providers and third-party marketers (who may combine your Personal Information with their own records and records available from other sources), for business or direct marketing purposes, and the direct marketing purposes of other third-party marketers.
11.5. Your privacy rights under CCPA11.5.1. The CCPA may permit you to request that we:Provide you the categories of Personal Information we have collected or disclosed about you in the last 12 (twelve) months; the categories of sources of such information; the business or commercial purpose for collecting your Personal Information; and the categories of third parties with whom we shared Personal Information;Provide a copy of your Data;Delete your Data;Disclose the identity of any third parties with whom we have shared Personal Information for the third-parties’ direct marketing purposes within the previous calendar year, along with the type of Personal Information disclosed;Do not discriminate against you for the exercise of the above rights. However, if you request us to delete your Data, we will not be able to provide the Services to you, since they are dependent on having access to your Data.
11.5.2. If you would like to exercise any of these rights, please contact us at the details provided in Clause 10 above. You will be required to verify your identify before we fulfill your request. 
11.6. We do not sell your Personal InformationUnder the CCPA, a business that sells California Consumers’ Personal Information to others: 1) must give notice to California Consumers before selling their Personal Information to others; and 2) must provide the right to opt out of the sale of their Personal Information. We do not sell Personal Information and will not sell it without providing a right to opt out to you.