Breezy Privacy Policy

We at Breezy Technologies, Inc. (“Breezy,” “we,” “us,” or “our”) value and respect your privacy. This Privacy Policy is meant to help you understand our data practices, and explains what personal data we collect about users of websites provided by Breezy, including www.breezy.com, www.underbuilt.com and any related websites (the “Sites”), our mobile applications, including the Breezy and Underbuilt applications (the “Apps”), and other technologies, features, content, and other services we offer (collectively, the “Services”).

We encourage you to read our entire Privacy Policy, but here are some basics:

• This Privacy Policy only applies to our Services. It does not apply to third-party websites, applications, products, services, or other properties, even if they may link to our Services or our Services may link to them. We recommend you review the privacy practices of those third parties before connecting with and/or accessing third-party offerings, and before sharing any personal data with those third parties.
• Breezy is the data controller of your personal data subject to this Privacy Policy. However, in some circumstances, Breezy acts as a data processor on behalf of real estate agents. For example, we provide technology that allows recordings and summaries of meetings with your agent, but your agent decides whether to activate that feature or ask for your consent. Also, real estate agents may enter certain personal information about their clients into the Customer Relationship Management (“CRM”) platform that we provide.
• We limit the data we collect, use, and share. We only collect, use, and share personal data as described in this Privacy Policy, in accordance with applicable law, or otherwise with your permission.
• We’re here for you if you have any questions or need support. Please Contact Us if you have any questions or concerns about our practices. If you are a visually impaired individual, an individual with another disability, or seek support in another language, you may access this Privacy Policy by emailing us at privacy@breezy.com.
• We want to be open with you about our data practices. We provide disclosures and rights in this Privacy Policy in the interest of transparency and our commitment to privacy. Such disclosures and rights are not intended to waive any applicable exemptions under state and federal law.

Linkable Table of Contents

For ease of review, below is a table of contents that links to each section. You can click on the headings to be taken to the full explanation.

1. Personal Data We May Collect, Use, and Disclose

As used in this Privacy Policy, “personal data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identifiable individual. Personal data includes “personal information” as that term is defined in applicable privacy laws.

Personal data does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been de-identified, or aggregate consumer information. “Publicly available information” includes information that is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media or by the individual; and information that is made available by a person to whom the individual has disclosed the information if the individual has not restricted the information to a specific audience.

We may create aggregated, de-identified, or anonymous information from personal data by removing certain data components (such as your name, email address, or linkable tracking identifier) that otherwise would make the data identifiable. We also create such aggregated, de-identified or anonymous data by obfuscating some data elements, compiling only non-personal data components, or through other means. Subject to applicable law, our use and disclosure of such aggregated, de-identified, or anonymized information is not personal data or subject to this Privacy Policy.

Because of the overlapping nature of certain of the categories of personal data identified above, some of the personal data we collect may be reasonably classified under multiple categories.

AI Training and Data Use

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (“AI Technologies”) to real estate agents. For example, a real estate agent may use our AI Technologies to summarize your property preferences or to summarize your communications with an agent.

We may use aggregated, anonymized user data to improve AI Technologies. However, none of your personal data will be used to train our AI Technologies without your consent.

2. Sources of Personal Data

We may collect personal data about you from the following categories of sources:

• Directly from you.
• Through cookies and other tracking technologies, as discussed in more detail in Cookies and Other Tracking Technologies.
• From other users of our Services, including real estate agents.
• From other third parties, including service providers, business and marketing partners, affiliates, analytics providers, ad network providers, ad agencies, advertisers, data co-ops, data brokers, Multiple Listing Service (“MLS”) feeds, and property APIs.
• From social media and other content platforms, such as Google, Facebook, Snapchat, and TikTok, if you interact with us on these platforms.

3. Disclosure of Personal Data

We may disclose personal data that we collect to the following:

• Our service providers. We disclose personal data with our service providers to provide services on our behalf, such as email, payment processing, analytics, advertising, hosting, marketing, customer and technical support, services that transcribe and summarize conversations, and other services.
• Advertising platforms. We may share your information with third-party platform providers, including advertising, social media, and analytics companies, who assist us in serving advertising regarding the Services to others who may be interested. We also partner with third parties who use cookies to serve interest-based advertising and content on their respective third-party platforms that may be based on your preferences, location and/or interests.
• Other Third Parties. We may share your information with other third parties including joint marketing campaign partners, data co-ops, data brokers, Third Party Businesses, and our agents.
• Compliance and harm prevention. Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities, and/or in response to a threat of harm involving an individual’s health and/or safety.
• Business transfers and transactions. If we or our subsidiaries are involved in a merger, acquisition, asset sale, or other corporate combination, your personal data may be transferred to the acquiring or surviving entity.

We may combine the personal data we receive from these third parties with personal data we otherwise collect about you through your use of our Services.

4. Cookies & Other Tracking Technologies

We use cookies and similar tracking technologies and analytics services to track activity on and gauge the effectiveness of our Sites. Cookies are files with a small amount of data which may include unique identifier. Cookies are sent to your browser from a website or mobile application and stored on your device. Other tracking technologies are also used such as beacons, tags, and scripts to collect and track information and to improve and analyze our Sites. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Sites.

A. Examples of cookies we use

Cookies on our Sites generally fall into the following categories:

• Strictly Necessary. We may use cookies that we consider are strictly necessary to allow you to use and access our Sites, including cookies required to prevent fraudulent activity, and improve security.
• Performance/Analytics. We may use cookies that are useful to assess the performance of our Sites, including as part of our analytic practices or otherwise to improve our Sites.
• Functionality. We may use cookies that are required to offer you enhanced functionality when accessing our Sites, including identifying you when you sign in to our website or keeping track of your specified preferences, including in terms of the presentation of content on our Site.
• Targeting or Advertising. We may use cookies to deliver content, including advertisements, relevant to your interests on our Sites based on how you interact with advertisements or content. We do not use your information for targeted advertising on third-party platforms.

B. Analytics Information

We may use Google Analytics or other service providers for analytics services. These analytics services may use cookies to help us analyze how users use the Service. Information generated by these services (e.g., your IP address and other usage information) may be transmitted to and stored by Google Analytics and other service providers on servers in the U.S. (or elsewhere) and these service providers may use this information for purposes such as evaluating your use of the Services, compiling statistic reports on the Service’s activity, and providing other services relating to Services activity and other Internet usage. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

5. Legal Bases for Processing

We rely on one or more legal bases to process your personal data under applicable law. We may process personal data (i) as necessary to perform our contractual obligations to you, including, but not limited to, those obligations in our Terms of Use; (ii) as necessary to pursue our legitimate business interests as further detailed below; (iii) as necessary for our compliance with our legal obligations such as a request or order from courts, law enforcement or other government authorities; and/or (iv) with your consent, including to send you marketing email messages and other information that may be of interest to you, which you may withdraw at any time.

We may collect, process, and maintain personal data to pursue the legitimate business interests outlined below. To determine these legitimate interests, we balance our legitimate interests against the legitimate interests and rights of you and others and only process personal data in accordance with those interests where they are not overridden by your data-protection interests or fundamental rights and freedoms.

Our legitimate interests generally include:

• Providing, improving, and developing our Services, including to deliver your requested services, send you messages and provide user support, customize the Services to better fit your needs as a user, develop new products and services, and perform internal analytics and research and development. This also includes sharing personal data with our trusted service providers that provide services on our behalf.
• Protecting you and others and creating and maintaining a trusted environment, such as to comply with our legal obligations, to ensure compliance with our agreements with you and other third parties, to ensure safe, secure, and reliable Services, and to detect and prevent wrongdoing and crime, assure compliance with our policies, and protect and defend our rights, interests, and property. In connection with the activities above, we may conduct internal research and profiling based on your interactions on various Services, content you submit to the Services, and information obtained from third parties.
• Providing, personalizing, measuring, and improving our marketing, including sending you promotional messages and other information that may be of interest to you with your consent. We may also use personal data to understand our user base and the effectiveness of our marketing. This processing is done pursuant to our legitimate interest in undertaking marketing activities to offer products or services that may be of interest to you.

6. Data Security

The security of your personal data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. We maintain appropriate technical, administrative and physical safeguards to help protect the security of your personal data against unauthorized access, destruction, loss, alteration, disclosure or misuse. We encourage you to secure your account with a strong password and to keep your password private.

7. Data Retention

We will retain your personal only for as long as is necessary to provide you with Services, to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will also retain certain personal data for internal analysis purposes. This information is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable given our legal position, including regard to applicable statutes of limitations, litigation, or regulatory investigations.

8. International Transfers of Data

We may transfer, store, and use information we collect and maintain about you, including personal data outside of your state, province, country or other governmental jurisdiction. For example, if you are located outside United States and choose to provide information to us, please note that we transfer personal data to United States and process it there.

The data protection laws in the jurisdiction in which we process personal data may differ from those of your jurisdiction, and in certain circumstances, your personal data may be subject to access requests from governments, courts, law enforcement agencies or regulatory agencies in those other jurisdictions.

9. Children’s Privacy

Our Services are not directed to or intended for children. We do not knowingly collect any personal data from anyone under the age of 18. If you become aware that a child has provided us with personal data, we strongly encourage you to Contact Us, and we will do our best to promptly remove such information from our records.

10. Your Choices & Rights

You may have certain choices and rights regarding our collection, use, and disclosure of your personal data, based on your location or place of residency.

A. Opting out of promotional electronic communications from us.

You may opt-out of any emails that we send for promotional purposes by clicking the “unsubscribe” links provided at the bottom of those emails. If you opt out of receiving promotional emails from us, we may still send you important administrative messages that are required to provide you with our Site or services or for other reasons disclosed in this Privacy Policy. This means you will continue to receive these emails even if you unsubscribe from our optional communications.

B. Accessing, updating, and deleting your account information.

If you have an account with us, you can access, correct, or update your account or other personal data by logging into Breezy and updating it via your user profile. You may also request that we delete your account by emailing support@breezy.com. Please note that we may retain your personal data even after you have deleted your account or personal data if reasonably necessary to comply with our legal obligations, resolve disputes, maintain security, detect and prevent fraud and abuse, enforce our Terms of Use, or fulfill your request to "unsubscribe" from further messages from us. We may also retain aggregate, de-identified, or anonymized data about you.

C. Additional rights available in certain states and jurisdictions.

Some jurisdictions provide individuals certain rights with respect to their personal data or personal data as defined under applicable law. These rights are subject to the specific laws of that jurisdiction and certain other rights might apply. Please review our Nevada Privacy Notice; Privacy Notice for Residents of Other U.S. States; Privacy Notice for Individuals in the EEA and UK; Privacy Notice for Individuals in Canada; and Privacy Notice for Individuals in Australia for more information on rights and terms specific to your location or place of residence. If any of the jurisdictional notices below apply to you, please use the following information to exercise your rights. Please send your request(s) by emailing us at: privacy@breezy.com.

Please note that any request you submit to us is subject to an identification and residency verification process as permitted under applicable law, as well as certain other procedural requirements that may be noted in the sections below. Additionally, all requests are subject to exceptions under applicable law, which may vary. If you are a visually-impaired customer or seek support in another language or format, you may access your privacy rights by emailing us at support@breezy.com.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, manifestly unfounded, or in accordance with applicable law. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Depending on applicable law, you may be limited in how many verifiable or authenticated consumer request you make within a twelve (12) month period. Additionally, in some jurisdictions, you may designate an authorized agent to submit a request on your behalf, and if so, we may require proof of the agent’s authorization by you and/or verification of the agent’s own identity.

Except where otherwise noted, we will respond to your request within forty-five (45) days after receipt and we reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days.

You are not required to create an account with us to submit a verifiable or authenticated consumer request. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal data associated with that specific account. We will only use personal data provided in a verifiable or authenticated consumer request to verify your (or your authorized agent’s as applicable) identity or authority to make the request. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

11. Nevada Privacy Notice

This Nevada Privacy Notice applies to visitors to www.underbuilt.com and users of Underbuilt mobile app. It does not apply to visitors to www.Breezy.com or users of the Breezy mobile application.

We may “sell” personal data as that term is defined under Nevada law. Nevada residents have the right to opt out of any future sale of their personal data under Nevada SB 220. If you are a Nevada resident and would like to make such a request, please follow the instructions in Your Privacy Choices & Rights. You must include your full name, email address, and postal address in your email or mail request so that we can verify your Nevada residence and respond. In the event we sell your personal data after receipt of your request, we will make reasonable efforts to comply with such request.

12. Privacy Notice for Residents of Other U.S. States

This Privacy Notice for Residents of Other U.S. States applies to visitors to www.underbuilt.com and users of Underbuilt mobile app. It does not apply to visitors to www.Breezy.com or users of the Breezy mobile application.

This section contains additional information for residents of Nebraska and Texas about personal data that we collect, how we use it, what sources it is derived from, and who we disclose it to, and provides information regarding your rights, and our responsibilities, under applicable laws and regulations.

The provisions contained within this section, in addition to the disclosures throughout the rest of this Privacy Policy, are intended to provide notices in compliance with the Connecticut Data Privacy Act, the Nebraska Data Privacy Act, and the Texas Data Privacy and Security Act (collectively, the “State Privacy Laws”).

This section does not apply to certain personal data that is collected from an individual in a business-to-business or employment context.

A. Our personal data practices.

The State Privacy Laws provide rights to residents of those states to receive certain disclosures and access regarding collection, use, sale, and sharing of personal data. More detail about what kinds of personal data we may collect or have collected, how we collect it, why we collect it, and who we may disclose it to is found in the Personal Data We May Collect, Use, and Disclose; Sources of Personal Data; and Disclosure of Personal Data sections of this Privacy Policy. As noted above, we do not collect sensitive personal data.

We may “sell” and/or “share” personal data with third party advertising networks and platforms for purposes of providing targeted behavioral advertising on those platforms. We may also “sell” and/or “share” personal data with other third parties including joint marketing campaign partners; data co-ops; data brokers; Third Party Businesses; and our agents.

B. Your privacy rights.

If you are a Connecticut, Nebraska, or Texas resident, you have the following rights under applicable law in relation to your personal data, subject to certain exceptions:

• Right to know and access. You have the right to know what personal data we collect, use, disclose, and/or sell or share as those terms are defined under applicable law. You may ask us to provide you a portable copy of this information up to two times in a rolling twelve-month period.
• Right to delete and erase. You have the right to request under certain circumstances that we, as well as our service providers and contractors, delete the personal data that we collect about you.
• Right to correct inaccurate personal data. You have the right to request the correction of inaccurate personal data.
• Right to non-discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
• Right to opt out. You have the right to opt-out of targeted advertising, our sale of your personal data, and profiling decisions that could produce legal or similarly significant effects concerning the consumer.
• Rights concerning sensitive personal data. We cannot process your sensitive data or your sensitive data inferences, or use your personal data for certain purposes without your affirmative consent.

C. How to exercise your rights.

You may exercise any of the rights described in this section by following the instructions in Your Privacy Choices & Rights.

D. How to appeal decisions about your rights.

Nebraska and Texas residents can appeal our decisions concerning privacy rights requests, as follows:

• Connecticut residents. If you are a Connecticut resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons for reaching the decision. If the appeal is denied, you may contact Connecticut’s Office of the Attorney General by phone at (860) 808-5420 or by submitting a form here.
• Nebraska residents. If you are a Nebraska resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Nebraska’s Office of the Attorney General by phone at (402) 471-2683 or by submitting a form here.
• Texas residents. If you are a Texas resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Texas’ Office of the Attorney General by phone at (800) 621-0508 or by submitting a form here.

13. Privacy Notice for Individuals in the EEA and UK

This Notice applies to any individuals located within the European Economic Area (“EEA”) and the United Kingdom (“UK”) about whom we may have collected personal data from any source, including through your use of the Sites. We provide this Notice in addition to the disclosures throughout the rest of this Privacy Policy to comply with applicable privacy laws, including the General Data Protection Act (“GDPR”) and the UK GDPR, and related laws, regulations, and guidance from the European Union and/or its member states (collectively, “European Privacy Laws”).

In certain circumstances, individuals located within the EEA and UK are entitled to the following privacy rights:

• Right to Access. You have the right to request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data.
• Right to Erasure. You have the right to request that we erase your personal data in certain circumstances provided by law.
• Right to Rectification. You have the right to request to have your personal data corrected or updated if that information is inaccurate, outdated, or incomplete.
• Right to Object to Processing. You have the right to object to our processing of your personal data.
• Right to Restrict Processing. You have the right to request that we restrict the processing of your personal data.
• Right to Data Portability. You have the right to request that we provide you with a copy of your personal data in a structured, machine-readable and commonly used format.
• Right to Withdraw Consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal data.
• Right to Lodge Complaint. You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.
  • A list of EU supervisory authorities is available here.
  • The relevant UK supervisory authority is the UK Information Commissioner’s Officer.

To exercise your privacy rights described above, please email us at privacy@breezy.com. Any request you submit to us is subject to an identification and residency verification process as permitted under applicable law. Additionally, all requests are subject to certain exceptions under applicable law, which may vary.

14. Privacy Notice for Individuals in Canada

This Notice applies to individuals in Canada about whom we may have collected personal data. We provide this Notice in addition to the disclosures throughout the rest of this Privacy Policy to comply with applicable laws, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and/or provincial privacy laws.

For the purposes of this Notice, "personal data" means information about an identifiable individual. Personal data does not include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, or work email address. Personal data also does not include information that has been de-identified, anonymized, or aggregated in such a way that there is no serious possibility it can be used to identify an individual, whether on its own or in combination with other available information.

• Right to Access. You have the right to request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data.
• Right to Correct. You have the right to request to have your personal data corrected or updated if that information is inaccurate, outdated, or incomplete.
• Right to Withdraw Consent. If you have already consented to the collection, use, and/or disclosure of your personal data, you may subsequently withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice.

To exercise your privacy rights described above, please email privacy@breezy.com. Any request you submit to us is subject to an identification and residency verification process as permitted under applicable law. Additionally, all requests are subject to certain exceptions under applicable law, which may vary. If you have any questions or concerns about our privacy practices, please email us at privacy@breezy.com.

You may also contact the Office of the Privacy Commissioner by calling (800) 282-1376 if you are unsatisfied with our response to your privacy concern.

15. Privacy Notice for Individuals in Australia

This Notice applies to any individuals located within Australia about whom we may have collected personal data. We provide this Notice in addition to the disclosures throughout the rest of this Privacy Policy to comply with applicable laws, including the Australia Privacy Act 1988.

In certain circumstances, individuals located within Australia are entitled to the following privacy rights, subject to certain exceptions:

• Right to Access. You have the right to request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data.
• Right to Correct. You have the right to request to have your personal data corrected or updated if that information is inaccurate, outdated, or incomplete.

To exercise your privacy rights, please email privacy@breezy.com. Any request you submit to us is subject to an identification and residency verification process as permitted under applicable law. Additionally, all requests are subject to certain exceptions under applicable law, which may vary.

16. Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will let you know about material changes via email and/or a prominent notice on our Services, prior to the changes becoming effective and will update the “Effective Date” at the top of this Privacy Policy. Changes to this Policy are effective when they are posted on this page.

17. Contact Us

If you have any questions about this Privacy Policy, please email us at privacy@breezy.com.

Google User Data Policy Compliance Addendum

Breezy's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

Breezy only accesses, uses, stores, or shares Google user data to provide and improve user-facing features of the Breezy platform — specifically for:

• Secure sign-in and authentication,
• Synchronizing calendar events, identifying meeting links, and generating meeting summaries, and
• Importing Google Contacts to help users manage their clients, listings, and property transactions within Breezy.

Breezy does not use Google user data for advertising, marketing, analytics unrelated to those features, or for any non-functional purpose.

All data access is read-only, encrypted in transit and at rest, and revoked immediately upon disconnection.

Breezy and its sub-processors (e.g. Recall.ai) act solely as data processors under user control and never use Google data for independent or secondary purposes.

Recall.ai

Purpose: Transcription and summarization of user video-conference meetings identified via Google Calendar event metadata.

Data Handled: Calendar event details (title, start/end time, conferencing URL, attendee emails) passed from Breezy; Recall.ai does not query or modify any data beyond what Breezy provides.

Access to Google APIs: Recall.ai accesses the user’s Google Calendar through Breezy-issued OAuth tokens solely to retrieve event data for transcription automation.

Security: All API calls and data transfers are encrypted (TLS 1.2+). Tokens are stored securely, used only for authorized meeting transcription, and destroyed upon revocation.

Retention: Transcription-related data is retained only as long as needed to generate meeting summaries, then deleted per Breezy’s data-retention policy.