Privacy Policy

Introduction

Locoraa LLC (“Locoraa,” “we,” “us,” or “our”), respects your privacy and is committed to protecting it through our compliance with this policy. Locoraa operates a lead generation and marketing service for real estate professionals through our website at locoraa.com and our related web and mobile applications, if any (the “Platform”). We provide an artificial-intelligence- assisted quiz that an individual who accesses the Platform other than in a professional capacity (the “Respondent”) may complete to receive personalized location and home search suggestions and, if the Respondent chooses, to be connected with a participating real estate agent, broker, or brokerage (the “Subscriber”), and we provide Subscribers with customer relationship management and marketing software to manage those connections. This policy describes:

The types of information we may collect or that you may provide when you access or use the Platform.
Our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy applies to information we collect on or through the Platform, and in email, text messages, and other electronic communications sent through or in connection with the Platform. It applies whether you access the Platform as a Respondent, as a Subscriber, or both. This policy does not apply to information that:
We collect offline or through any other means, including on any other website or service operated by us.
You provide to, or that is collected by, any third party, including Subscribers, our payment processor, and other applications, websites, or content that may link to or be accessible from the Platform (see “How We Disclose Your Information” and “Third-Party Information Collection”). Subscribers, payment processors, and other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them. We are not responsible for the privacy practices of any Subscriber or other third party. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not use the Platform. By accessing or using the Platform, you agree to this privacy policy. This policy may change from time to time (see “Changes to Our Privacy Policy”). Your continued use of the Platform after we revise this policy means you accept those changes, so please check the policy periodically for updates.

Children Under the Age of 18

The Platform is intended for users who are at least 18 years of age, and it is not directed to children. By using the Platform, completing the quiz, or opting in to receive text messages, you represent that you are at least 18 years old. We do not knowingly collect personal information from anyone under 18, and in no event do we knowingly collect personal information from children under 13. If you are under 18, do not use the Platform, do not complete the quiz, do not create an account, and do not provide any information about yourself to us, including your name, phone number, or email address. If we learn that we have collected or received personal information from a child under 13 (or, where a higher age threshold applies under applicable law, under that age), we will delete that information. If you believe we might have any information from or about a child under the applicable age, please contact us at privacy@locoraa.com.

Information We Collect and How We Collect It

We collect several types of information from and about users of the Platform, including information:

By which you may be personally identified, such as your name, phone number, email address, or other identifiers by which you may be contacted online or offline (“personal information”).
That is about you but does not individually identify you, such as device and usage information. We collect this information:
Directly from you when you provide it to us.
Automatically as you navigate through or interact with the Platform.
From third parties, for example our payment processor, our hosting and messaging providers, and Subscribers.

Information You Provide to Us

The information we collect on or through the Platform depends on how you use it and whether you act as a Respondent, a Subscriber, or both. This information may include:

Quiz responses. The preferences, priorities, budget indications, target locations, timing, and free-form answers you submit while taking the quiz. We do not ask for, and you should not submit, government identification numbers, financial account numbers, health information, or other sensitive personal information through the quiz.
Respondent contact information. We collect your email address when you submit the quiz so that we can deliver your results. If you choose to be connected with a real estate professional, we also collect the name, telephone number, and any other contact details you submit for that purpose.
SMS opt-in and consent records. If you opt in to receive text messages, we collect and store your mobile telephone number, the date and time of your opt-in, the IP address from which it was submitted, the language of the consent presented to you, and a record of your consent, together with any subsequent opt-out.
Subscriber account information. If you subscribe as a Subscriber, we collect your full legal name, business or brokerage name, license information, email address, telephone number, and billing contact details, together with the content you create or upload, including profile information, marketing materials, message templates, campaign content, notes, and images.
Payment information. Subscription payments are processed by our third-party payment service provider (the “Payment Processor”). Your payment card and billing details are collected and stored by the Payment Processor under its own privacy policy. We receive only limited transaction information, such as the last four digits of the card, the billing name, and the transaction result.
Correspondence. Records and copies of your correspondence (including email addresses and phone numbers) if you contact us, or if you contact a Subscriber through the Platform.
Form information. Information that you provide by filling in forms on the Platform, including at the time of creating an account, subscribing to our service, requesting further services, entering a contest or promotion sponsored by us, or reporting a problem with the Platform.
Survey responses. Your responses to surveys that we might ask you to complete for research purposes. Subscribers may also provide information for publication or display on public or shared areas of the Platform, such as agent profiles and marketing content (the “User Contributions”). User Contributions are transmitted to others at your own risk. We cannot control the actions of other users or third parties with whom such information is shared, and we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with the Platform, we and our service providers may collect certain information about your device and your browsing and usage activity, including:

Usage details. Details of your access to and use of the Platform, including traffic data, logs, the pages or screens you view, your progress through the quiz, the features you use, and the dates and times of your activity.
Device information. Information about your computer or mobile device and internet connection, including your IP address, device identifier, operating system, browser type, and, for mobile devices, mobile network information.
Location information. Approximate location derived from your IP address. We do not collect precise (GPS-level) real-time location from your device unless you grant permission through your device settings, and we describe any such collection at the point we request it. We use these technologies for a limited set of purposes: to keep the Platform secure, to remember your progress and answers while you are taking the quiz, to record your consent where required, and to perform first-party analytics that help us diagnose issues and improve the Platform. We do not use cookies, pixels, or similar technologies to deliver targeted or interest- based advertising, we do not permit third-party advertising networks to collect information about you through the Platform, and we do not engage in cross-context behavioral advertising. If this changes, we will update this policy and provide the choices required by applicable law before the change takes effect.

Third-Party Information Collection

When you use the Platform, certain third parties may collect information about you or your device in the course of providing services to us or to you. These third parties may include:

Our Payment Processor.
Our hosting, infrastructure, database, and security providers.
Our email and SMS messaging providers and the mobile carriers that deliver messages to you.
Our artificial intelligence service providers, as described in “Artificial Intelligence and Automated Processing”.
The Subscriber to whom you have asked to be connected, and that Subscriber’s own service providers.
Your mobile device manufacturer and your mobile service provider. We do not control these third parties’ technologies or how they may be used. If you have questions about a third party’s practices, you should contact the responsible provider directly.

How We Use Your Information

We use information that we collect about you, or that you provide to us, including any personal information, to:

Provide, operate, and maintain the Platform and its features.
Generate personalized location and home search suggestions based on your quiz responses.
Match you with, and deliver your contact details and quiz responses to, the Subscriber you have asked to be connected with. If that Subscriber’s subscription lapses or is cancelled, your information may instead be handled by Locoraa personnel so that we can respond to your request or undertake the appropriate action to address it.
Create and manage Subscriber accounts and verify the identity of Subscribers.
Enable Subscribers to receive, manage, contact, and market to the individuals who elect to be connected with them.
Process subscription payments, calculate and collect our fees, and handle billing disputes through our Payment Processor.
Detect, prevent, and address fraud, abuse, security incidents, and other prohibited or illegal activity, and to protect the rights, property, and safety of Locoraa, our users, and others.
Send you transactional and relationship messages, including quiz result confirmations, match notifications, receipts, and notices about your account or changes to our terms or policies.
Send you marketing and promotional communications, and enable Subscribers to send follow-up and marketing communications, in each case subject to the choices described in “Communications and Marketing” and “Choices About How We Use and Disclose Your Information”.
Analyze usage and trends, measure the effectiveness of the Platform and our communications, and improve and personalize the Platform.
Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
Comply with our legal obligations and respond to lawful requests from public authorities.
Fulfill any other purpose for which you provide the information, or with your consent.

How We Disclose Your Information

We may disclose aggregated or de-identified information that does not identify any individual without restriction. In addition, we may disclose personal information that we collect or that you provide as described in this policy, including:

To the Subscriber you select, at your direction. When a Respondent elects to be connected with a real estate professional, the contact information and quiz responses that Respondent submits are disclosed to the applicable Subscriber at the Respondent’s request and direction. Once that disclosure is made, the Subscriber becomes an independent controller of the information and is solely responsible for its own handling of it, including its own privacy notices, retention practices, and communications. We do not sell, rent, or otherwise transfer Respondent information to any person other than the Subscriber the Respondent has asked to be connected with.
To service providers. We disclose personal information to contractors, service providers, and other third parties we use to support our business, including our Payment Processor, hosting and infrastructure providers, communications and messaging providers, analytics providers, and artificial intelligence providers. These providers are bound by contractual obligations to keep personal information confidential and to use it only for the purposes for which we disclose it to them.
To our affiliates. We may disclose personal information to our subsidiaries and affiliates for the purposes described in this policy.
For business transfers. We may disclose personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Locoraa’s assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding.
For legal and safety purposes. We may disclose personal information to comply with any court order, law, or legal process, including to respond to any government or regulatory request; to enforce our Terms of Use and other agreements; and if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Locoraa, our users, or others, including for fraud protection and risk reduction.
With your consent. We may disclose your personal information for any other purpose with your consent. We do not sell your personal information, and we do not share your personal information with any third party for that third party’s own advertising or marketing purposes.

Except as detailed herein or unless you expressly consent, no mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All of the categories described above exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties, except as otherwise detailed herein. Your mobile telephone number, SMS opt-in data, and consent records are never sold, rented, or disclosed to any third party, partner, or affiliate for that party’s own marketing or promotional purposes. We use them solely to send, and to keep records of your consent to receive, the messages you asked for, and we disclose them only to the messaging platforms and carriers that deliver those messages on our behalf and to the Subscriber you have affirmatively asked to be connected with, in each case at your direction and for that purpose alone.

Cookies and Similar Technologies

We and our service providers may use a limited set of cookies and similar technologies to operate and secure the Platform. These may include:

Strictly necessary cookies. Cookies and local browser storage required to run the Platform, authenticate users, maintain session security, and prevent fraud and abuse.
Functional storage. Local browser storage that may be used to remember your progress and answers while you are taking the quiz, so that you do not lose them if you navigate away or reload the page.
First-party analytics. Measurement technologies used to understand how the Platform is used in aggregate, to diagnose technical problems, and to improve performance. We do not use advertising cookies, third-party advertising pixels, or cross-site tracking technologies, and we do not permit third parties to collect information about your activity across other websites or services through the Platform. You can set your browser to refuse all or some cookies, or to alert you when cookies are being sent, and you can clear local browser storage through your browser settings. If you disable or refuse cookies or local storage, some parts of the Platform may become inaccessible or may not function properly, and you may be unable to complete the quiz.

Communications and Marketing

We and Subscribers may send a variety of messages by email and SMS text message. These include:

Transactional and relationship messages, such as quiz result confirmations, match notifications, account notices, and subscription receipts.
Recommendation updates, match follow-ups, and related messages from Locoraa, where you have opted in to receive them.
Follow-up and marketing messages from the Subscriber you have asked to be connected with, which may be generated and sent by automated means on that Subscriber’s behalf. That Subscriber is responsible for ensuring it has the necessary rights and consents to contact you and for honoring your opt-out requests.
Marketing communications from Locoraa about the Platform and our services. Consent to receive marketing text messages is not a condition of purchasing any property, goods, or services. Message frequency varies based on your interaction with the Platform. Message and data rates may apply. You can opt out of marketing emails by following the unsubscribe instructions in the message, and you can opt out of marketing text messages by replying STOP to any message, after which you will receive a single confirmation message and no further marketing messages from that sender. Reply HELP for assistance or contact us as described in “Contact Information”. Mobile carriers are not liable for delayed or undelivered messages. Even if you opt out of marketing communications, we may still send you transactional and relationship messages about your account and your requests. Marketing text messages and emails are also regulated under federal and state law. At the federal level, marketing text messages are subject to the Telephone Consumer Protection Act (the “TCPA”) and the implementing rules of the Federal Communications Commission, which generally require the sender to obtain the recipient’s prior express written consent before sending marketing or promotional text messages, to identify the sender, to honor opt-out requests (such as replying STOP), and to observe limits on the times of day when messages may be sent. Marketing emails are separately regulated under the federal CAN-SPAM Act, which generally requires accurate sender and subject-line information, identification of the message as an advertisement, inclusion of a valid physical postal address, and a working opt-out mechanism. In addition, a growing number of states, including Florida, Oklahoma, Washington, and Texas, have enacted their own telemarketing and text-messaging laws (often called “mini-TCPA” laws) that may impose stricter consent, disclosure, timing, and opt-out requirements, and that in some cases allow consumers to bring claims directly. The specific requirements vary and depend on the nature of the message and the recipient’s location. Subscribers that use the Platform to send follow-up, marketing, or other communications are responsible for complying with these laws, including the TCPA, the CAN-SPAM Act, federal and state do-not-call rules, and any applicable state laws. This includes obtaining any legally required consent from the people they contact, clearly identifying themselves, honoring opt-out and STOP requests, observing applicable timing restrictions, and maintaining records of consent. By using the Platform to contact others, each Subscriber represents that it has the necessary rights and consents to do so, and Locoraa is not responsible for a Subscriber’s communications with the individuals it contacts.

Artificial Intelligence and Automated Processing

We use artificial intelligence, machine learning, and other automated systems to generate quiz questions and recommendations, to analyze quiz responses, to score, route, and prioritize matches, to generate marketing and follow-up communications for Subscribers and, where a Subscriber uses our automated sending features, to send those communications on the Subscriber’s behalf, and to operate and improve the Platform. Output generated by these systems may be produced without human review, may be incomplete or inaccurate, and is provided for general informational purposes only. Follow-up and marketing messages that you receive from a Subscriber may be generated and sent by these automated systems on that Subscriber’s behalf, without individual review of each message by the Subscriber before it is sent. It does not constitute real estate, brokerage, appraisal, mortgage, lending, investment, tax, financial, or legal advice. We do not use automated processing to make decisions that produce legal or similarly significant effects concerning you. If that changes, we will update this policy and provide the notice and choices required by applicable law.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. These include:

Whether to submit contact information. You must provide your email address to view your quiz results. Submitting any other contact information is optional, and we deliver your information to a Subscriber only if you affirmatively ask to be connected.
Marketing communications. You can opt out of marketing emails and text messages as described in “Communications and Marketing”. To stop receiving communications from a Subscriber after your information has been delivered, reply STOP to that Subscriber’s messages, use the unsubscribe link in its emails, or contact the Subscriber directly.
Tracking technologies. You can set your browser to refuse all or some browser cookies, to alert you when cookies are being sent, or to clear local storage. If you disable or refuse cookies or local storage, some parts of the Platform may become inaccessible or may not function properly.
Opt-out preference signals. Where required by law, we honor opt-out preference signals such as the Global Privacy Control (GPC) transmitted by your browser or device.
Location. You can control collection of location information through your device or browser settings.

Accessing and Correcting Your Information

If you are a Subscriber, you can review and change certain personal information by logging into your account and visiting your account settings. You may also contact us as described in “Contact Information” to request access to, correction of, or deletion of personal information you have provided to us, including your quiz history and contact details. We may be unable to delete certain information except by also closing your account, and we may decline a request where permitted or required by law, including where we believe a requested change would violate any law or legal requirement or cause the information to be incorrect. If your information has already been delivered to a Subscriber at your request, that Subscriber holds its own independent copy. Deleting your information from our systems does not delete it from the Subscriber’s systems, and you will need to contact that Subscriber directly to exercise any rights you have with respect to the copy it holds. We will, on request, tell you which Subscriber received your information. Residents of certain states, such as California, may have additional rights and choices regarding their personal information. Please see “Your U.S. State Privacy Rights” for more information.

Your U.S. State Privacy Rights

Several U.S. states have enacted consumer privacy laws that give their residents additional rights regarding their personal information. The rights described below apply only to the extent the relevant law applies to our processing of your personal information, and they are subject to certain exceptions and verification requirements.

California Residents

Subject to certain exceptions, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the “CCPA”), provides California residents with the following rights:

Right to know and access. You may request the categories and specific pieces of personal information we have collected about you, the categories of sources, the business or commercial purposes for collecting it, and the categories of third parties to whom we disclose it.
Right to delete. You may request that we delete personal information we collected from you, subject to certain exceptions.
Right to correct. You may request that we correct inaccurate personal information we maintain about you.
Right to opt out of sale or sharing. You may opt out of the “sale” or “sharing” (including for cross-context behavioral advertising) of your personal information. We do not sell or share personal information as those terms are defined by the CCPA. Delivery of your information to the Subscriber you have asked to be connected with is made at your direction and for the purpose you requested.
Right to limit use of sensitive personal information. To the extent we use sensitive personal information for purposes beyond those permitted by the CCPA, you may direct us to limit that use. We do not request sensitive personal information through the quiz.
Right to non-discrimination. We will not discriminate against you for exercising any of your CCPA rights. To exercise these rights, please contact us using the methods described in “Contact Information”. We will verify your request before responding, and you may use an authorized agent to submit a request on your behalf. California’s “Shine the Light” law (Civil Code § 1798.83) also permits California residents to request information about our disclosure of personal information to third parties for their direct marketing purposes; to make such a request, please contact us.

Florida and Other U.S. States

Locoraa LLC is organized under the laws of the State of Florida. The Florida Digital Bill of Rights and comparable laws in many states, including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia, provide (now or in the future) their residents with rights to:

Confirm whether we process their personal information, and access that information.
Delete certain personal information.
Correct inaccuracies in their personal information, taking into account the nature and purpose of the processing (excluding Iowa and Utah).
Obtain a portable copy of their personal information.
Opt out of the processing of personal information for targeted advertising (excluding Iowa), sales, and profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
Either limit (opt out of) or consent to the processing of sensitive personal data and the personal data of minors. The exact scope of these rights varies by state. To exercise any of these rights, please contact us using the methods described in “Contact Information”. If we decline to act on your request, you may appeal that decision by contacting us; if we deny your appeal, you may contact your state attorney general. Nevada residents have a limited right to opt out of certain sales of personal information. Residents who wish to exercise this right may submit a request to us as described in “Contact Information”. We do not currently sell personal information in a manner that triggers that statute’s opt-out requirement.

Users Located Outside the United States

The Platform is operated from the United States. Locoraa is based in the United States, and the personal information we collect is processed and stored in the United States and other countries where we or our service providers operate. These countries may have data protection laws that differ from those in your country. Where we transfer personal information originating from the European Economic Area, the United Kingdom, or Switzerland to a country that has not been found to provide an adequate level of data protection, we implement appropriate safeguards for the transfer. If you access the Platform from outside the United States, you understand that your information will be transferred to, stored, and processed in the United States. Users in the European Economic Area, the United Kingdom, and Switzerland If you are located in the European Economic Area, the United Kingdom, or Switzerland, Locoraa LLC may be deemed the controller of the personal information collected through the Platform, and once your information has been delivered to a Subscriber at your request, that Subscriber is a separate and independent controller of its copy. We process your personal information on the following legal bases: your consent (including for delivering your information to the Subscriber you ask to be connected with and for marketing communications, which you may withdraw at any time), the performance of a contract with you, our legitimate interests (such as securing and improving the Platform and preventing fraud), and compliance with our legal obligations. Subject to applicable law, you have the right to request access to, correction of, erasure of, restriction of, or a portable copy of your personal information, to object to processing based on our legitimate interests, and to object at any time to processing for direct marketing; we do not make decisions based solely on automated processing that produce legal or similarly significant effects concerning you. To exercise these rights, contact us as described in "Contact Information" (we may need to verify your identity), and you may also lodge a complaint with your local supervisory authority, the UK Information Commissioner's Office, or the Swiss Federal Data Protection and Information Commissioner. Your personal information is transferred to and processed in the United States as described above and retained as described in "Data Retention".

Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including to provide the Platform, comply with our legal, accounting, tax, or reporting obligations, resolve disputes, enforce our agreements, and prevent fraud. Records of SMS consent and opt-out are retained for at least the period required to demonstrate compliance with applicable telemarketing laws.

Changes to Our Privacy Policy

We may update this privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will notify you by email to the address associated with your account or through a notice on the Platform. The date this policy was last revised is identified at the top of the page. You are responsible for ensuring that we have an up-to-date, active, and deliverable email address and phone number for you, and for periodically reviewing this policy for changes. When we amend this policy, we will post the updated policy, revise the “Last modified” date above, and, for material changes, provide notice as described above before the changes take effect. By continuing to access or use the Platform after the effective date of an updated policy, you acknowledge the changes and agree to be bound by the amended policy. Where applicable law requires your express or affirmative consent to a particular change or to a specific use of your personal information, we will obtain that consent through the means required by law, such as a clickthrough “I Accept” or a separate opt-in.

Contact Information

To ask questions or comment about this privacy policy or our privacy practices, or to exercise your privacy rights, please contact us at: Email: privacy@locoraa.com Mailing address: 7901 4th St N Ste 300 St. Petersburg, FL 33702