ENRG Realty Privacy Policy and Data Processing Policy

1. Introduction

ENRG Realty LLC ("ENRG Realty," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your Personal Information when you:

• Visit our websites and mobile applications (collectively, the "ENRG Realty Sites"),
• Interact with us offline or through other communications,
• Receive our real estate brokerage services or otherwise engage with ENRG Realty.

If you have any questions about this Privacy Policy or our data practices, you may contact our Privacy Officer at privacy@enrg.realty. You can also use our Individual Rights Request Form to exercise certain data rights, including the right to opt out of specific types of data processing.

2. To Whom This Privacy Policy Applies

This Privacy Policy applies to:

• Users of the ENRG Realty Sites, which includes any website or mobile application under our control.
• ENRG Realty Real Estate Agents, Employees, and Consultants with respect to Personal Information collected via our Sites or in connection with our services.
• Clients (e.g., prospective or current buyers, sellers, landlords, tenants) who engage our independent contractor real estate agents or brokers, including Personal Information we receive as part of delivering our real estate Services.

If you reside in a jurisdiction that grants you additional privacy rights or imposes certain obligations on businesses (e.g., states such as California, Virginia, or Colorado), additional or different provisions may apply to you. Please refer to Section 20 for more details.

3. Who We Are

We operate across multiple states and partner with a network of independent contractor real estate agents and affiliates. In this Privacy Policy, all references to "ENRG Realty" include any subsidiary or affiliated entity to the extent that it collects or processes Personal Information on behalf of ENRG Realty.

4. Our Data Values

At ENRG Realty, our data handling practices are guided by the following core principles:

Purpose-Driven Collection

We collect only the Personal Information needed to provide and improve our real estate brokerage services.

Responsible Use

We adhere to strict contractual and policy-based obligations when sharing Personal Information with affiliates, service providers, and third-party partners.

Transparency and Security

We aim to be clear about our data practices, ensuring that individuals understand how their information is collected, used, and shared. We also employ security safeguards to protect Personal Information against unauthorized access.

5. Your Data Rights

Depending on your geographic location, you may have specific rights regarding your Personal Information, such as:

• The right to request access to, or obtain a copy of, your Personal Information.
• The right to request corrections to inaccurate or incomplete Personal Information.
• The right to request deletion of certain Personal Information (subject to legal exceptions).
• The right to opt out of certain sharing or selling of your Personal Information.

To exercise these rights, please use our Individual Rights Request Form or contact us at privacy@enrg.realty. We will respond in accordance with applicable laws and may request additional information to verify your identity.

6. Scope: What This Privacy Policy Covers

This Privacy Policy covers how ENRG Realty collects, uses, and discloses Personal Information from you in the following scenarios:

• When you visit, interact with, or use our ENRG Realty Sites (e.g., browsing property listings, creating an online account).
• When you communicate with us offline (e.g., phone calls, events) or online (e.g., email, text, chat).
• When you engage our licensed real estate agents or brokers to provide real estate services (e.g., listing, buying, selling, leasing properties).
• When we work with affiliates, partners, or other third parties to provide additional services such as mortgage or title insurance referrals.

7. Consent to This Privacy Policy

By using our Sites or Services, or by otherwise providing Personal Information to us, you acknowledge that you have read and understand this Privacy Policy. If you do not agree with any provision in this Privacy Policy, please discontinue use of our Sites and Services.

We may also request your explicit consent for certain data processing activities (for example, if required by law for certain types of sensitive data or in jurisdictions where explicit consent is mandatory).

8. Information We Collect

A. Personal Information

Depending on how you interact with us, we may collect the following types of Personal Information:

• Contact Details: Name, email address, postal address, phone number, and similar identifiers.
• Real Estate Transaction Details: Information related to buying, selling, or leasing properties (e.g., property addresses, listing agreements, property preferences, loan details, or disclosures required by law).
• Account Credentials: Username, password, or similar security credentials if you create an online account.
• Demographic Data: Such as age, nationality, or other data you voluntarily provide.
• Communications: If you communicate with us by email, phone, text, or otherwise, we may collect your correspondence, including call recordings where permitted by law.

B. Usage Information

We also collect certain technical data regarding your visits or usage of our Sites or Services:

• IP Address and Device Identifiers: Information about the devices you use, including IP address, mobile device ID, or other unique device identifiers.
• Log Information: Browser type, operating system, domain name system requests, pages viewed, referring/exit pages, date/time stamps, and clickstream data.
• Cookies and Similar Technologies: We use cookies, web beacons, and other tracking mechanisms to improve user experience, analyze trends, and provide relevant advertisements. You can manage cookie preferences in your browser or device settings.

9. How We Collect Your Information

Directly from You

• When you voluntarily provide Personal Information (e.g., filling out forms on our Sites, requesting information about listings, or communicating with us).
• When you complete real estate transaction paperwork or documentation with our agents or staff.

Automatically

• Via cookies or tracking technologies when you browse our Sites or open certain emails.
• Through log files and analytics tools that monitor usage patterns and diagnose technical issues.

From Third Parties

We may receive Personal Information from multiple listing services (MLS), affiliate companies, lead-generation partners, or other third parties who assist in facilitating your transaction or providing related services (title, mortgage, insurance, etc.).

Combined Data

We may combine data we receive from various sources (e.g., offline interactions, third-party data, online usage data) to improve our Services and better understand user needs.

10. How We Use Your Information

ENRG Realty uses your Personal Information for the following business and commercial purposes:

Service Delivery and Transactions

• Facilitating property searches, showings, and real estate transactions.
• Administering user accounts and enabling property listing or viewing features.
• Communicating about listings, offers, and related opportunities.

Internal Operations and Improvement

• Conducting market research, internal analytics, and usage trend analysis.
• Enhancing user experience and designing new site features or services.
• Monitoring and preventing fraud, security breaches, or unauthorized activities.

Marketing and Communications

• Sending informational or promotional materials about our Services, property listings, or affiliated offerings (e.g., mortgage, title, or insurance) in accordance with your preferences or applicable laws.
• Personalizing ad content on our Sites or third-party platforms.

Legal Compliance and Other Obligations

• Complying with applicable real estate laws, regulations, or industry standards.
• Fulfilling legal requirements, responding to lawful requests, and protecting ENRG Realty's rights, property, or safety.

Other Uses with Consent

For any additional purpose with your explicit consent (e.g., certain advanced data analytics or third-party marketing outside the scope described above).

11. Disclosure of Personal Information

We do not sell your Personal Information in exchange for monetary compensation. However, we may share Personal Information for business or commercial purposes as follows:

With Our Agents and Subsidiaries

To facilitate a real estate transaction you have requested. For example, if you are a buyer, your contact details may be shared with a listing agent or cooperating broker. If you are a seller, details about your property listing will be shared with potential buyers.

Service Providers and Partners

We may engage trusted affiliates, service providers, or other third parties (e.g., technology providers, marketing agencies, attorneys, accountants, and title or escrow services) who require access to your Personal Information to perform services on our behalf.

Contractual protections ensure they use such data only for agreed-upon purposes.

Compliance with Law and Protection

• We may disclose Personal Information if required to do so by law, regulation, subpoena, or other legal process.
• We may also share information when we believe it is necessary to enforce our agreements, protect our rights or the rights of others, or investigate fraud or security issues.

Corporate Transactions

Personal Information may be transferred in the event of an acquisition, merger, sale of assets, financing, bankruptcy, or reorganization. The acquiring entity will be bound by this Privacy Policy regarding your Personal Information.

Aggregated or De-Identified Data

We may share de-identified, aggregated, or otherwise non-personally identifiable information (e.g., market analytics) with third parties for any lawful purpose.

12. Your Choices with Personal Information

Access, Correction, and Deletion

You may request access to, or correction of, certain Personal Information we hold about you. In some circumstances, you may also request deletion of your data. Submit a request via our Individual Rights Request Form or email privacy@enrg.realty.

Opt-Out of Marketing

You can unsubscribe from marketing communications by clicking "unsubscribe" in any promotional email or updating your account preferences. We will continue to send non-marketing messages (e.g., transaction or legal updates) as necessary.

Cookie Management

Your browser or device may allow you to block or limit cookies. Disabling certain cookies may prevent you from fully enjoying certain Site features.

Do Not Sell or Share My Personal Data

If your jurisdiction treats certain data sharing as a "sale" or "share," you can opt out by completing the Do Not Sell or Share My Personal Data form on our website or contacting privacy@enrg.realty.

13. "Do Not Track" Signals

Some web browsers offer a "Do Not Track" (DNT) preference. Currently, there is no broadly accepted industry standard for recognizing and responding to DNT signals. ENRG Realty will treat DNT signals in accordance with applicable laws, but we cannot guarantee that all features will function as intended if DNT is enabled.

14. Age Requirements; Children's Information

Our Sites and Services are not intended for use by individuals under the age of 13. We do not knowingly collect Personal Information from children under 13. If we become aware that a child under 13 has provided Personal Information to us without parental consent, we will delete that information.

15. International Data Transfers

We primarily store and process Personal Information in the United States. If you access our Sites or use our Services from outside the United States, your information will be transferred to and processed in the U.S. By using our Sites or Services, you agree to such transfer, storage, and processing in the U.S. and any other jurisdictions where our affiliates or service providers operate.

16. Data Transfers upon Change in Company Control

In the event that ENRG Realty experiences a corporate transaction (e.g., a merger, acquisition, sale of assets, reorganization, bankruptcy), your Personal Information may be transferred as part of that transaction. Any acquiring entity will be bound by this Privacy Policy regarding the Personal Information it receives, unless you are otherwise notified.

17. Data Retention and Security Measures

Data Retention

We retain Personal Information for as long as necessary to fulfill the purposes outlined in this Privacy Policy or comply with legal, regulatory, or contractual obligations.

Security Safeguards

We have implemented organizational and technical measures (e.g., encryption, restricted access, data minimization, and staff training) to secure Personal Information against unauthorized access, theft, or misuse.

However, no security measure can guarantee absolute safety. In the event of a data breach, we will notify affected individuals and relevant authorities in accordance with applicable laws.

18. Reviewing and Correcting Your Personal Information

You may request to review or correct your Personal Information by contacting us at privacy@enrg.realty. In some cases, we may request additional information to verify your identity or clarify your request.

19. Links to Other Sites

Our Sites or services may contain links to external websites, services, or social media platforms. While we strive to link only to trusted sites, we are not responsible for the security or privacy practices of external sites. We encourage you to review the privacy policies of any third-party site or service you visit.

20. Your Rights Based on Geographic Location

Some jurisdictions provide additional rights regarding the collection and use of Personal Information. For instance, certain states in the U.S. (e.g., California, Virginia, Colorado) may grant rights such as:

• Right to access or obtain a copy of your Personal Information.
• Right to correct inaccuracies or request deletion.
• Right to opt out of targeted advertising, data sharing, or profiling.
• Right to nondiscrimination for exercising any privacy rights.

To learn more, please review our Supplemental State-Specific Privacy Notices (if applicable) or contact privacy@enrg.realty.

21. Accessibility

ENRG Realty is committed to ensuring our Sites are accessible to individuals with disabilities. If you need assistance accessing this Privacy Policy or have any questions about accessibility, please contact us at privacy@enrg.realty.

22. Complaints

If you believe we have not addressed your privacy-related concerns or that we have processed your Personal Information in violation of applicable law, you may file a complaint:

• Contact Us Directly: Email privacy@enrg.realty or write to the address below.
• Regulatory Authorities: Depending on your country or state, you may have the right to lodge a complaint with a relevant data protection authority or real estate regulatory body.

23. Contact Us