Privacy Policy

I. Introduction

At Propy, Inc., a Delaware corporation (“Propy,” collectively with its affiliates, the “Propy Companies,” “us,” “our,” or “we”) we take your privacy and the security of your information very seriously.

This Privacy Policy (“Policy”) describes the types of information we may collect from you or that you may provide when you visit our Site at https://propy.com/ and any subdomains thereof (the “Site”), and any services offered by the Propy Companies (collectively, the “Services”), and describes our practices for collecting, using, maintaining, protecting, and disclosing that information. This Policy is available at https://propy.com/privacy-policy. This Policy governs your access to the Services. Unless otherwise defined herein, capitalized terms shall have the meaning assigned to such terms in the Terms of Use. “NFT” in this Policy means a non-fungible token or similar digital item implemented on a blockchain (e.g. the Ethereum blockchain), which uses smart contracts to link to or otherwise be associated with certain content or data.

This Policy covers both users who merely interact with the Site or the Services hosted on the Site and users who create an account on the Site (each an “User”). References herein to “you” may refer to Users. By interacting with the Site, or using any of the Services, you agree to be bound by this Policy. This Policy does not govern information we receive from third parties who are not Users. If you do not agree to the terms of this Policy, please do not visit the Site, or use any of our Services. Each time you visit the Site, or use our Services, the current version of this Policy will apply. Accordingly, when you visit the Site, or use any of our Services, you should check the date of this Policy (which appears at the top) and review any changes since you last reviewed the Policy.

II. Children and Privacy

The Site is not intended for children under 18 years of age. No one under the age of 18 may provide any information to or on the Site. We do not knowingly collect Personal Information from children under 18. If you are under 18, do not use or provide any information on this Site through any of their features, create an account on the Site, use any of the interactive or public comment features of the Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at support@propy.com.

III. Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Site, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number, social security number, or any other identifier by which you may be contacted online or offline (“Personal Information”);
• That is about you but individually does not identify you, such as information relating to a property address and photos of a property you intend to sell on the Site; and/or
• About your internet connection, the equipment you use to access our Site, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the Site. Information collected automatically may include your computer’s Internet Protocol (“IP”) address (a number that provides an address for your computer), your computer’s operating system, blockchain address, wallet type, date/time stamps, type and language, device identifier numbers, and information collected through cookies. You can learn more from our cookies privacy here.
• From third parties, for example, when you use your account through a social network, such as Facebook. Through Facebook’s login feature, we will obtain access to certain information including your name, profile picture and email in accordance with the authorization procedures determined by such a third party. Other similar sources may include Google Sign-In, Google Play, iOS.

Information You Provide to Us

The information we collect on or through our Site may include:

• Information that you provide by filling in forms on our Site. This includes information provided at the time of creating an account to use our Site, posting material, or requesting further Services. We may also ask you for information when you participate in the purchase or sale of real estate on the Site, and when you report a problem with our Site.
  
• Records and copies of your correspondence (including email addresses), if you contact us.
  
• Details of transactions you carry out through our Site. You may be required to provide financial information before carrying out any transactions through our Site.
  
• Your search queries on the Site.

You also may provide information to be published or displayed on public areas of the Site or transmitted to other users of the Site or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. Therefore, 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 our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include Personal Information. The collection of Personal Information helps us to improve our Site and to deliver a better and more personalized experience, including by enabling us to:

• Estimate our audience size and usage patterns.
• Speed up your searches.
• Recognize you when you return to our Site.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site.

Flash Cookies. Certain features of our Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Section VII, “Choices About How We Use and Disclose Your Information.”

Web Beacons. Pages of our Site and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related Site statistics (for example, recording the popularity of certain Site content and verifying system and server integrity).

Information Collected from Third-Party Companies

We may receive Personal and/or Anonymous Information (as defined herein) about you from companies that offer their products and/or services for use in conjunction with our Services or whose products and/or services may be linked from our Services. “Anonymous Information” means information, including aggregated and de-identified data, that is not associated with or linked to your Personal Information; Anonymous Information does not, by itself, permit the identification of individual persons. For example, third-party wallet providers provide us with your blockchain address and certain other information you choose to share with those wallets providers. We may add this to the data we have already collected from or about you through our Services.

Public Information Observed from Blockchains

We collect data from activity that is publicly visible and/or accessible on blockchains. This may include blockchain addresses and information regarding purchases, sales, or transfers of NFTs, which may then be associated with other information you have provided to us.

IV. How We Use Your Information

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

• To present our Site and its contents, and the Services to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Site or any products or Services we offer or provide though it.
• To allow you to participate in interactive features on our Site.
• To provide you information about new services and newsletters.
• To monitor the usage of our Services and analyze emerging trends.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. In addition, we may publicly display information of real estate agents who have created an account on the Site, including, without limitation, Personal Information, the number of successfully closed real estate transactions on the Site, the real estate agent’s property listings, the number of offers received for the real estate agent’s property listings, and certain certifications (e.g., the real estate agent’s certification, ‘Crypto Certified Agent Course,’ etc.).

V. Disclosure of Your Information

We may disclose aggregated information about our Users, and information that does not identify any individual, without restriction.

We may disclose Personal Information that we collect, or you provide, as described in this Policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
• 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 Propy’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Propy about our Users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your Personal Information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Propy, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

VI. Third-Party Wallets

To use our Services, you must use a third-party wallet which allows you to engage in transactions on public blockchains. Your interactions with any third-party wallet provider are governed by the applicable terms of service and privacy policy of that third party.

Your transactions through the Services will be recorded on the blockchain and associated with your wallet ID.

VII. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s Site. If you disable or refuse cookies, please note that some parts of the Site may then be inaccessible or not function properly.
• Promotional Offers from the Company. If you do not wish to have your email address used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to our Data Protection Officer (DPO) at dpo@propy.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s Site.

California residents may have additional Personal Information rights and choices. Please see Section IX, “Your California Privacy Rights” for more information.

VIII. Accessing or Correcting Your Information

You can review and change your Personal Information by logging into the Site and visiting your account profile page.

You may also send an email to our Data Protection Officer (DPO) at dpo@propy.com to request access to, correct or delete any Personal Information that you have provided to us. We cannot delete your Personal Information except by also deleting your User account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Site, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Users. Proper access and use of information provided on the Site, including User Contributions, is governed by our Terms of Use.

We cannot edit or delete any information that is stored on a blockchain (e.g. the Ethereum blockchain) as we do not have custody or control over any blockchains. The information stored on the blockchain may include purchases, sales, and transfers related to your blockchain address and NFTs and cryptocurrencies held at that address.

California residents may have additional Personal Information rights and choices. Please see Section IX, “Your California Privacy Rights” for more information.

IX. Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccpa.

X. Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Site. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

If you believe that your account on the Site has been accessed without your authorization, or if you have received any email or other communication purporting to be from us requesting your password or asking you to provide sensitive account information via email, please report it immediately to our DPO at dpo@propy.com. You must promptly notify us if you become aware that any information provided by or submitted to the Site is lost, stolen, or used without permission.

XI. Changes to Our Privacy Policy

It is our policy to post any changes we make to this Policy on this page. If we make material changes to how we treat our Users’ Personal Information, we will notify you through a notice on the Site home page. The date this Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this Policy to check for any changes.

XII. How Do I Contact Propy?

To contact us with your questions or comments regarding this Policy or the information collection and dissemination practices of Propy relevant to your use of the Services, please email us at support@propy.com.