1. Introduction

BrokerTech, LLC ("we," "us," or "our") operates the Coordnator mobile application and web platform (collectively, the "Service"). Coordnator is a real estate brokerage management platform that helps agents, brokers, and administrative staff manage transactions, vendors, documents, and communications.

This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our Service. By using Coordnator, you agree to the collection and use of information as described in this policy.

2. Information We Collect

2a. Information You Provide Directly

• Account Information: Name, email address, phone number, and password when you create an account.
• Profile Information: Profile photo, date of birth, real estate license number, brokerage affiliation, professional contact details, and any other information you or your brokerage administrator add to your profile.
• Transaction Data: Property addresses, transaction details, deadlines, buyer/seller information, associated documents, and any other information you or your brokerage add to a transaction.
• Documents: Files you upload to the document repository, including contracts, disclosures, and other real estate-related documents.
• Contracts and Forms: Real estate contracts, purchase agreements, disclosure forms, and other documents created or completed through the platform.
• Electronic Signatures: When you sign documents electronically through the Service, we collect and retain your e-signature, the signed document, signing timestamps, IP address at the time of signing, and related audit trail records necessary to establish the validity and enforceability of the signed document.
• Photos and Images: Images you select from your device's photo library when uploading a profile picture, adding images to brokerage news posts, or uploading logos for external application integrations. These images are transmitted to our servers and stored in our cloud infrastructure. We do not access photos or images beyond what you explicitly select and upload.
• Vendor Reviews: Ratings and written reviews you submit for vendors listed in the platform.
• Communications: Messages, support tickets, and other communications you send through or about the Service.
• Other Submitted Information: Any other information that you, your brokerage, or an authorized user within your brokerage submit to the Service in the course of using the platform.

2b. Information Collected Automatically

• Device Information: Device type, operating system, unique device identifiers, and mobile network information.
• Push Notification Tokens: If you enable push notifications, we collect your device's push notification token so that we can deliver transaction updates, deadline reminders, and other service-related notifications to your device. You can disable push notifications at any time through your device settings.
• Location Data: Approximate location derived from your IP address, which we use for authentication and security purposes (such as detecting unusual login activity). If you use features such as the showing agent service area map or the vendor search by location, we may request access to your device's precise GPS location with your permission. For example, the showing agent service area feature uses your location to center a map so you can define the geographic areas where you provide showing services, and the vendor search uses your location to find nearby service providers. You may deny or revoke location permission at any time through your device settings, though some location-dependent features may not function without it.
• Authentication Tokens and Credentials: Session tokens and credentials used to keep you securely signed in. If you use passkey-based login, only the public credential is stored on our servers; private keys remain on your device and are never transmitted to us.
• Usage Data: Features accessed, screens viewed, actions taken within the app, and timestamps of activity.
• Log Data: IP addresses, browser type, referring/exit pages, and server logs generated when you interact with our Service.

2c. Information from Third Parties

• Brokerage Data: Your brokerage administrator may provide information about your role, permissions, and affiliation within the platform.
• MLS Data: Property listing data sourced from Multiple Listing Service (MLS) providers in connection with your transactions.

2d. Sensitive Data Categories

Certain state privacy laws require us to specifically identify categories of sensitive data we collect. Of the categories identified under these laws, Coordnator collects the following:

• Account Passwords: We collect and store account passwords that you create during registration or account setup. Passwords are stored in hashed form and are not accessible in plain text by our staff.
• Passkey Credentials: If you use passkey-based login, we store the public credential identifier associated with your device. The private key remains on your device and is never transmitted to us.

Coordnator does not collect social security numbers, driver’s license or government-issued identification numbers, financial account numbers, health insurance account numbers or medical identification numbers, biometric data, or security questions and answers.

3. Device Permissions

Coordnator may request access to certain features on your device. Each permission is optional, and we explain below what each permission is used for and how the associated data is handled:

Permission	Purpose and Examples
Camera	Coordnator may request access to your device's camera to allow you to take a new photo for use as your profile picture. For example, when updating your profile photo in Settings, you can choose to take a photo with your camera instead of selecting an existing image from your photo library. Photos taken with the camera are uploaded to our servers and stored as your profile image. We do not access your camera in the background or for any purpose other than capturing a photo you have explicitly chosen to take.
Photo Library	Coordnator requests access to your photo library so you can select existing images from your device. For example, you may choose a photo from your library to set as your profile picture, attach an image to a brokerage news post or event, or upload a logo for an external application integration. Only the specific images you select are accessed and uploaded; we do not browse or access other photos in your library.
Location	Used for location-based features such as defining your showing agent service area on a map (so you can specify the geographic region where you provide showing services) and finding nearby vendors by distance. Location data is used only while the app is in use and is not tracked in the background.
Notifications	Used to send you real-time alerts about your transactions, such as deadline reminders, new document signatures requested, showing request updates, and other time-sensitive brokerage communications. You can manage notification preferences within the app or disable them entirely through your device settings.

You can grant or revoke any of these permissions at any time through your device's Settings app. Revoking a permission may limit the functionality of features that depend on it, but will not affect the core functionality of the app.

4. How We Use Your Information

We use the information we collect for the following purposes:

• Providing the Service: To operate, maintain, and deliver the features of Coordnator, including transaction management, vendor directories, document repositories, user profiles, push notifications, and geographic service area functionality for showing agents.
• Authentication and Security: To verify your identity, manage your account, enforce role-based access controls, detect unusual login activity using IP-based location data, and protect against unauthorized access or fraudulent activity.
• Communication: To send you service-related notifications, including transaction updates, deadline reminders, document signing requests, and platform announcements via push notifications, SMS, or email.
• Improvement: To understand how our Service is used, diagnose technical issues, and develop new features and improvements.
• Compliance: To comply with applicable legal obligations (including Do Not Call Registry compliance for brokerages), resolve disputes, and enforce our terms of service.

5. How We Share Your Information

We do not sell your personal information. We may share your information in the following limited circumstances:

• Within Your Brokerage: Your profile information, transaction data, and activity may be visible to other authorized users within your brokerage, based on role-based access controls set by your brokerage administrator.
• Transaction Participants: When you are involved in a real estate transaction, certain information (such as your name, email, and role) may be shared with other parties to the transaction, including cooperating agents, buyers, sellers, and their representatives, as necessary to facilitate the transaction.
• Vendors: If you submit a review for a vendor, your name and review content may be visible to other users of the platform.
• Service Providers: We use third-party service providers to help us operate the Service. These providers process data on our behalf and are contractually obligated to protect your information. The categories of service providers we use include cloud hosting and data storage, electronic signature processing, email delivery and validation, push notification delivery, and map and geocoding services.
• Legal Requirements: We may disclose your information if required to do so by law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of BrokerTech, LLC, our users, or others.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

We do not sell, rent, or trade your personal information to third parties for marketing purposes. Specifically, no mobile information — including SMS opt-in data, phone numbers, and messaging consent — will be shared with third parties or affiliates for marketing or promotional purposes.

6. Data Storage and Security

Your data is stored on secure infrastructure hosted in the United States. We implement industry-standard security measures to protect your information, including:

• Encryption of data in transit and at rest.
• Secure authentication and session management.
• Role-based access controls that restrict data access based on your brokerage role and permissions.
• Intrusion detection, rate limiting, and other server-side protections.
• Regular security assessments and updates.

While we take reasonable steps to protect your personal information, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security.

7. Electronic Signatures and Record Retention

Coordnator enables the creation of real estate contracts, forms, and documents, and may facilitate the collection of electronic signatures. In connection with these features:

• We maintain e-signature audit trails, including signer identity, timestamps, and IP addresses, as required to comply with the federal Electronic Signatures in Global and National Commerce Act (E-SIGN Act) and applicable state laws such as the Uniform Electronic Transactions Act (UETA).
• Signed documents and their associated audit records are retained for the duration required by your brokerage's record-keeping policies and applicable real estate regulations, which may extend well beyond the closure of a transaction or the deactivation of your account.
• These records cannot be deleted upon individual request where retention is required by law or by your brokerage's legal and regulatory obligations.

8. Data Retention

We retain your personal information for as long as your account is active or as needed to provide you with the Service. Specifically:

• Account Data: Retained while your account is active and for a reasonable period afterward in case of reactivation.
• Transaction Data: Retained in accordance with real estate record-keeping requirements and your brokerage's policies.
• Contracts, Forms, and E-Signature Records: Retained for the period required by applicable law, regulatory requirements, and your brokerage's record retention policies. In many jurisdictions, real estate transaction records must be retained for a minimum period (commonly 5 to 7 years or longer) after the close of a transaction.
• Documents and Images: Retained until you or your brokerage administrator delete them, or as required by applicable law.
• Push Notification Tokens: Retained while your account is active. Tokens are automatically invalidated when you log out or uninstall the app.
• Do Not Call Records: DNC check audit logs are retained for a minimum of 5 years as required by FTC regulations.
• Email Delivery Records: Email send logs and delivery event records are retained for compliance and troubleshooting purposes.
• Log and Usage Data: Generally retained for up to 12 months for security and analytical purposes.

9. Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information:

Right	Description
Confirmation	Confirm whether or not we are processing your personal data.
Access	Request a copy of the personal information we hold about you.
Obtain	Obtain the specific personal data we have collected concerning you in a readily usable format.
Correction	Request that we correct inaccurate or incomplete personal information.
Deletion	Request that we delete your personal information, subject to brokerage retention requirements and applicable legal exceptions (see Section 8).
Portability	Request a portable copy of your data in a commonly used format.
Profiling and Automated Decisions	Question the results of any automated processing of your personal data that produces legal or similarly significant effects concerning you, such as decisions related to contract generation, electronic signature workflows, or compliance determinations. You may request information about the logic used in such processing and submit a request for human review.
Opt-Out	Opt out of non-essential communications from us. You may also disable push notifications through your device settings at any time.
Appeal	Appeal any refusal to act on a privacy rights request by contacting us at the information provided in Section 14.

To exercise any of these rights, please contact us using the information in Section 14 below. We will respond to your request within 30 days, or as required by applicable law.

10. State-Specific Privacy Rights

Minnesota Residents

BrokerTech, LLC is headquartered in Minnesota. If you are a Minnesota resident, you have rights under the Minnesota Consumer Data Privacy Act (Minn. Stat. § 325M et. seq.), including but not limited to:

• The right to confirm whether we are processing your personal data and to access that data.
• The right to correct inaccuracies in your personal data.
• The right to delete your personal data, subject to applicable exceptions.
• The right to obtain the personal data we have collected concerning you.
• The right to obtain a portable copy of your personal data.
• The right to opt out of the processing of personal data concerning you for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of automated decisions that produce legal effects concerning you or similarly significant effects concerning you.
• The right to question the results of automated processing that produces legal or similarly significant effects concerning you and to request meaningful information about the logic used in such processing.
• The right to appeal any refusal to act on your request.

As disclosed in Section 2d of this agreement, the only category of sensitive data (as defined by Minn. Stat. § 325M.14 Subd. 4 (i)) that we collect is account passwords (stored in hashed form). We do not collect social security numbers, driver’s license numbers, financial account numbers, health insurance or medical identification numbers, biometric data, or security questions and answers.

To exercise any of these rights, contact us using the information in Section 14 of this agreement.

California Residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), including the right to know what personal information we collect, the right to delete your personal information, and the right to opt out of the sale of your personal information. As stated above, we do not sell personal information.

Other States

Many states have enacted comprehensive consumer privacy laws, including but not limited to Virginia, Colorado, Connecticut, Texas, Oregon, Montana, Delaware, Iowa, Indiana, Tennessee, New Jersey, New Hampshire, Nebraska, Maryland, Kentucky, and others. If you reside in a state with applicable consumer privacy legislation, you may exercise the rights provided to you under your state’s law, including rights of access, correction, deletion, portability, and opt-out. To exercise any such rights or to learn more about how your state’s law applies, please contact us using the information in Section 14.

11. Children's Privacy

Coordnator is a professional business tool designed for licensed real estate professionals and brokerage staff. Our Service is not directed at children under the age of 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will take steps to delete that information promptly.

12. Third-Party Links and Services

Our Service may contain links to third-party websites, services, or integrations (such as MLS providers, external brokerage tools, and transaction management platforms). We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will notify you by updating the "Last Updated" date at the top of this page and, where appropriate, through in-app notifications. Your continued use of the Service after any changes constitutes your acceptance of the updated policy.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: