Crit

CRT HOLDING GROUP LLC ("crit.homes")
Last Updated: 1/24/2025

1. Introduction

This comprehensive Privacy Policy ("Policy") sets forth the principles, practices, and procedures governing the collection, use, storage, protection, and disclosure of personal information and other data by CRT HOLDING GROUP LLC ("we," "us," "our," or the "Company") in connection with your access to and use of crit.homes (the "Platform"). We are steadfastly committed to safeguarding your privacy and ensuring transparency in how your information is handled. This Policy has been carefully crafted to provide you with a detailed understanding of our data practices and your rights regarding your personal information.

2. Information We Collect

The Company systematically collects and processes various categories of information through both direct user input and automated systems. This information is essential for the operation, improvement, and personalization of our services.

2.1 Information You Provide

In the course of using our Platform, you may voluntarily provide the following categories of personal information:

Account credentials and authentication information, including but not limited to your full legal name, email address, and securely encrypted password
Detailed profile information encompassing your real estate experience level, geographical location preferences, and other relevant demographic data
User-generated content in the form of property reviews, ratings, and associated commentary
Records and transcripts of communications between you and our customer service team, including but not limited to emails, chat logs, and support tickets
Financial information processed securely through our payment processor, Stripe, including payment card details and billing addresses

2.2 Automatically Collected Information

Through your interaction with our Platform, we automatically collect and process the following technical and usage information:

Device-specific information, including but not limited to browser type and version, operating system, hardware model, unique device identifiers, and IP address
Comprehensive usage analytics, including detailed metrics regarding pages visited, features accessed, time spent on various Platform components, and interaction patterns
Precise geolocation data when submitting property reviews, subject to your explicit consent and device settings
Cookie data and similar tracking technologies used to maintain session state, remember preferences, and analyze Platform usage patterns
Server logs containing technical details about your connections to our Platform, including timestamps, request details, and system performance metrics

2.3 Location Information

Our Platform collects and processes location data for the following specific purposes:

To authenticate and verify physical presence at properties during the review submission process, ensuring the integrity and reliability of our review system
To provide geographically relevant property listings and recommendations based on your current location and specified search preferences
To implement robust fraud prevention measures and maintain the authenticity of user-generated content
To enhance the overall user experience through location-aware features and functionalities

While Users maintain the option to disable location services through their device settings, please be advised that such action may result in limited Platform functionality, particularly regarding the submission of verified property reviews and access to location-specific features.

3. How We Use Your Information

The Company employs collected information for various essential purposes, each designed to enhance and maintain the Platform's functionality and user experience. Specifically, we utilize the collected data to:

Operate, maintain, and continuously improve the Platform's core functionality and user interface
Implement and execute robust verification protocols for property visits through our proprietary geolocation system
Facilitate the efficient display, moderation, and management of user-submitted reviews and associated content
Establish and maintain effective communication channels with users regarding Platform updates, security notices, and support inquiries
Process and secure financial transactions through our designated payment processing partner, Stripe
Deploy and maintain comprehensive fraud prevention measures to protect the Platform's integrity
Ensure ongoing compliance with applicable legal obligations and regulatory requirements
Conduct detailed analysis of Platform usage patterns to inform product development and service improvements
Deliver personalized user experiences through algorithmic content curation and preference-based recommendations

4. Information Sharing

4.1 Authorized Information Sharing

The Company may share certain information with the following categories of recipients, subject to strict confidentiality and data protection requirements:

Trusted service providers who assist in essential Platform operations, including but not limited to hosting infrastructure providers and payment processing services
Law enforcement authorities, regulatory bodies, or legal representatives in response to valid legal process or as mandated by applicable laws and regulations
Property owners or their authorized agents solely in connection with legitimate dispute resolution processes, subject to appropriate confidentiality protections
Strategic business partners, provided that explicit user consent has been obtained and appropriate data protection agreements are in place
Licensed real estate agents and brokers who are registered users of the Platform, for the purpose of facilitating real estate transactions and providing relevant services to users who have expressed interest in property listings
Marketing partners and lead generation services who assist in connecting users with relevant real estate professionals

4.2 Information Sharing and Lead Generation

The Company maintains the following practices regarding information sharing and lead generation:

User information may be packaged and sold as leads to qualified real estate professionals on the Platform
Lead information may include contact details, property preferences, and user-provided information relevant to real estate transactions
Users can opt-out of lead generation programs through their account settings
Payment information remains secured and is never shared beyond our designated payment processor

5. Data Security

The Company implements and maintains comprehensive security measures designed to protect user information from unauthorized access, disclosure, alteration, or destruction. Our security infrastructure includes:

Industry-standard encryption protocols for all sensitive data transmission and storage, including but not limited to AES-256 encryption and TLS 1.3 protocols
Regular and systematic security assessments, penetration testing, and vulnerability scanning conducted by qualified security professionals
Strictly enforced access controls and authentication procedures limiting employee access to user data on a need-to-know basis
Redundant and secure data storage systems with regular backup procedures and disaster recovery protocols

6. Your Rights and Choices

Users are hereby granted and entitled to exercise the following comprehensive rights regarding their personal information:

The right to access and obtain a copy of all personal information maintained by the Platform about the user
The right to request correction or updating of any inaccurate, incomplete, or outdated personal information
The right to request complete deletion of their account and associated personal information, subject to legal retention requirements
The right to opt-out of non-essential communications and marketing messages through readily accessible preference controls
The right to control and modify location sharing permissions through device settings and Platform preferences
The right to export their data in a structured, commonly used, and machine-readable format
The right to opt-out of having personal information sold or shared as leads through readily accessible account settings
For California residents, the right to opt-out of the sale of personal information as required by the CCPA

7. Cookies and Tracking Technologies

The Platform employs cookies and similar tracking technologies for the following purposes:

Session management and authentication, including maintaining secure user sessions and preserving essential user preferences
Storage and retrieval of user preferences and settings to enhance Platform usability and personalization
Collection and analysis of usage metrics to improve Platform performance and user experience
Implementation of security measures to protect against unauthorized access and fraudulent activities
Third-party tracking and analytics, including but not limited to Facebook Pixel, Google Analytics, and similar services for advertising and marketing purposes
Retargeting and behavioral advertising across third-party platforms and services

Users maintain control over cookie settings through their browser preferences and can manage third-party tracking preferences through our cookie consent banner. Modification of such settings may impact certain Platform functionalities.

8. Third-Party Services

8.1 Integration of Third-Party Services

The Platform integrates with the following categories of third-party service providers to deliver essential functionality:

Stripe payment processing services for secure handling of financial transactions and payment information
Analytics providers for the collection and analysis of Platform usage data and performance metrics
Mapping service providers for location-based features and geographical data visualization
Multiple Listing Service (MLS) data providers for real estate listing information and property details

8.2 Third-Party Privacy Practices

Users acknowledge and understand the following regarding third-party services:

The Platform does not exercise control over the privacy practices or policies of third-party service providers
Users are strongly encouraged to review the privacy policies of all third-party services accessed through the Platform
Users should exercise appropriate caution when accessing external websites or services through links provided on the Platform

9. Children's Privacy Protections

The Platform maintains strict policies regarding the privacy of children:

The Platform does not knowingly collect, store, or process personal information from individuals under the age of thirteen (13)
Parents or legal guardians may submit requests for the deletion of any inadvertently collected information about children
Upon verification of parental authority, any such information will be promptly removed from our systems

10. Data Retention Policies

The Platform retains personal information in accordance with the following principles:

Information is retained for the duration necessary to provide requested services and maintain essential Platform functionality
Retention periods are determined by applicable legal requirements and regulatory obligations
User data is retained until account deletion, subject to legal and operational requirements
Certain information may be retained for extended periods as necessary for fraud prevention and security purposes

11. International Data Processing

Users acknowledge the following regarding international data handling:

All data processing operations are conducted within the United States of America
By utilizing the Platform, users explicitly consent to the international transfer and processing of their personal information
The Platform maintains compliance with applicable international data protection laws and regulations
Additional safeguards are implemented for international data transfers as required by applicable law

12. Policy Updates and Modifications

The Platform reserves the right to modify this Privacy Policy under the following conditions:

Material changes will be communicated to users through prominent notice at least thirty (30) days prior to implementation
Non-material modifications may take effect immediately upon posting of the updated Privacy Policy
Previous versions of the Privacy Policy remain available upon request for user reference
Continued use of the Platform following any modification constitutes acceptance of the updated Privacy Policy

13. Location Services

The Platform implements specific protocols and safeguards regarding the collection, processing, and storage of location data, as detailed below:

Location data is collected exclusively during the review submission process to verify physical presence at the property being reviewed
All location data is encrypted and stored using industry-standard security protocols in conjunction with the associated review data
Location information is utilized solely for the purpose of review verification and fraud prevention
Under no circumstances is precise location data shared with other users or third parties, except as required by law
Users maintain complete control over location permissions through their device settings and may revoke access at any time

14. Review Privacy

The following provisions govern the privacy aspects of user-submitted reviews and associated content:

All reviews submitted to the Platform are publicly visible and accessible to all users and visitors
Anonymous review submissions are strictly prohibited; all reviews are associated with the submitting user's account
Each review displays a verification status indicating whether location verification was successfully completed
Users may request the deletion of their reviews, subject to Platform review and approval
The Platform reserves the right to maintain archived copies of deleted reviews for legal and compliance purposes

15. Account Closure

Upon account closure or termination, the following data retention and handling procedures apply:

Previously submitted reviews remain publicly accessible on the Platform unless explicitly requested otherwise
Personal identification data is permanently deleted from active systems within thirty (30) days of account closure
Certain data may be retained in encrypted backup systems or as required by law for legitimate business purposes
Backup data containing personal information is systematically purged according to established retention schedules
Users may request complete deletion of all associated data, subject to legal retention requirements

16. Data Breach Procedures

In the event of a data security breach, the Platform will execute the following comprehensive response protocol:

Affected users will be notified via email within seventy-two (72) hours of breach confirmation
A thorough investigation will be conducted to determine the scope and impact of the security incident
Appropriate corrective measures will be implemented to prevent similar incidents in the future
All applicable data breach notification laws and regulations will be strictly followed
Regular updates will be provided to affected users throughout the resolution process

17. Contact Us

For any inquiries, concerns, or requests regarding this Privacy Policy or our data practices:

Email: legal@crit.homes for all privacy-related communications
Mailing Address: 80 N Gould Street STE R, Sheridan, WY 82801
Response Time: We strive to respond to all privacy-related inquiries within five (5) business days
Written Requests: For formal requests, please submit via certified mail to our physical address

18. California Privacy Rights

California residents are entitled to the following additional privacy rights under applicable state law:

The right to know what personal information is being collected and how it is being used
The right to request deletion of personal information, subject to certain exceptions
The right to opt-out of the sale of personal information to third parties, including real estate professionals, through our "Do Not Sell My Personal Information" page accessible at crit.homes/privacy/do-not-sell
The right to non-discrimination for exercising their privacy rights
The right to access their personal information in a portable and readily usable format

19. GDPR Compliance

For users in the European Union, we maintain the following additional privacy protections:

Transparent documentation of the legal basis for all data processing activities
Implementation of appropriate safeguards for international data transfers
Recognition of the right to lodge complaints with supervisory authorities
Acknowledgment of the right to withdraw consent at any time
Appointment of a Data Protection Officer for oversight of compliance measures

20. Effective Date

This Privacy Policy is effective as of January 13, 2025, and supersedes all previous versions. The Platform maintains archived copies of all prior privacy policies for user reference and regulatory compliance purposes.